Category Archives: International Tax
May 30, 2018
The Tax Cuts and Jobs Act slashes business income tax rates on certain types of business income.
- The 20% Qualified Business Income Tax Deduction slashes the top individual income tax rate on certain business income from 37% to 6%.
- The 37.5% Foreign-Derived Intangible Income (FDII) Deduction slashes the C corporation income
“Tax-Favored” Foreign Income: Planning Pointers and Traps, An Overview of the FDII and GILTI DeductionsMay 24, 2018
The Tax Cuts and Jobs Act (TCJA) reduces the corporate income tax rates of C corporations to 21 percent. The TCJA further reduces the C corporation income arising from tax-favored foreign income by means of two deductions:
- The Foreign-Derived Intangible Income (FDII) deduction equals 37.5 percent of FDII and results
March 15, 2018
The IRS announced it will be closing its Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018. The news follows a significant decrease in taxpayer participation in the program, coupled with advances in third-party reporting of offshore account information and increased awareness of reporting obligations. All submissions made by the deadline must ...
February 19, 2018
Wire Transfer Audits and FATCA
What Every Taxpayer Needs to Know
by Attorney Morris N. Robinson, CPA, LLM
February 19, 2018
1. FATCAFATCA: The Foreign Account Tax Compliance Act was signed into law by President Obama on March 18, 2010. There ...
November 15, 2017
Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On November 3, 2017, IRS announced the identification of an additional 11 compliance campaigns to be conducted by ...
June 22, 2017
If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect. New FBAR Civil Penalties Framework The statutory civil penalties most people are familiar with, and as reflected ...
June 14, 2017
In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their ...
May 15, 2017
Attorney Morris N. Robinson, the Managing Director of M. Robinson Tax Law in Boston, recently published an op-ed titled: Viewpoint: A 15 percent tax rate on business would maximize economic growth (Boston Business Journal, May 5, 2017, subscription required).
April 5, 2017
We represent a client who may need to file delinquent international information returns under the IRS Delinquent International Information Return Submission Procedures. These procedures invite taxpayers who meet the specified criteria to “file the delinquent information returns with a statement of all facts establishing reasonable cause for the failure to file.”
Building Wealth through Real Estate: Financial and Tax Policies of the United States Government That Can Lead To Significant Wealth through Real Estate OwnershipDecember 23, 2016
Financial and tax policies of the United States government can help Americans achieve significant wealth through real estate ownership. These policies tend to favor taxpayers who, like the Trump family, are willing to commit to "the long game”, where the full benefits of real estate ownership accrue over decades and ...