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Taxing Foreign Corporations
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Taxing Foreign Corporations in the Digital Age

Effectively Connected Income and it's Tax Consequences Foreign entities that deliver digital goods and services using the internet as a point of distribution may be subject to U.S. income tax. The nature and character of the goods and services…
Qualified Business Income Deduction 2

Good News for Rental Property Owners; Qualified Business Deduction

Business Income Deduction for Taxpayer On September 24, 2019, the IRS issued Revenue Procedure 2019-38  now permitting  certain taxpayers who hold an interest  or interests in rental real estate to be treated as a trade or business for purposes…
TFR and Fraudulent conveyances
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Trust Fund Recovery Penalty; Consequences of Fraudulent Conveyances

Fraudulent Conveyances in Employment Taxes Employers who willfully fail to remit an employee’s withholding to the IRS are liable to the IRS for the “trust fund recovery penalty” (TFRP). Generally, the IRS will assess the Penalty against…
Tax relief for renouncing citizenship 1
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Tax Relief for Expats who Renounce U.S. Citizenship

Relief Procedures for former U.S. Citizens The new procedures attempt to address problems faced by some U.S. citizens, whose only connection with the United States is that they were born in America. Many of these individuals have been living…
Employment taxes, IRS and workers classification

Employment Tax Consequences with Workers Misclassification

Employee versus Independent Contractor Deciding whether to classify an individual as an employee or independent contractor is a decision which requires a careful evaluation of many factors and the assistance of a tax attorney. A…
IRS Data Analytics

IRS Detection of Tax Fraud Proliferates

Data Analytics is the Key During the last decade, the Internal Revenue Service has been limited in its ability to ferret out tax cheats, due, in large part, to a 17% cut in its budget in 2010 as well as a 14% reduction in its labor force. Despite…
Tax bill
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Residency Based Taxation Legislation Provides False Hope for U.S. Expats

 Citizen Based Taxation The origins of citizen based taxation can be traced back to the Civil War and the government’s struggle to raise revenue for the war effort. The predicate for imposing such a system was based upon the notion that…
constructive dividents

 Personal Expenses paid by a Corporation are Constructive Dividends

Combs v. Commissioner Case Taxpayers who operate small closely held businesses using a corporate entity need to be mindful that personal expenses, paid from a corporate bank account or the use of a corporate credit card for personal reasons…
GSA US Tax Court bldg 450x450

Willful FBAR Penalty Moving Towards a Strict Liability Standard

Assessment of the “willful” FBAR penalty Courts have sustained FBAR penalties by reference to case law which is inconsistent with standards and principals applied in penalty cases under Title 26, despite the punitive nature of the willful…
fbar quiet disclosure
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Offshore Disclosure of Foreign Financial Accounts: Deciding What Road to Take

Disclosing Offshore Bank Accounts Taxpayers who are considering coming out of the shadows to disclose their offshore accounts need to be extremely careful when deciding what road to take. Too often, taxpayers simply default to the cheapest…