TaxConnections


 

Wanted: Head of Tax/Treasury (Silicon Valley)

TaxConnections has been retained by a very successful high technology company in Silicon Valley. The Head of Tax will work closely with C – Suite Executives in managing and reviewing global corporate tax compliance, the global tax provision, transfer pricing and treasury strategy. Responsibilities include managing global outside tax consultants and reviewing processes and procedures. The Head of Tax will partner with internal business leaders to effectively manage exposure. The role requires an individual who can effectively communicate with internal and external partners and provide business options to management executives. The ability to understand the company’s products and monitor transactions to identify areas of risk and tax opportunity it important.

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Taxpayer Advocate Service Provides Self-Help Tools to Assist Taxpayers With Complex Affordable Care Act Requirements

Nina Olson, Taxpayer Advocate

With the open enrollment period for the Health Insurance Marketplace beginning November 1st, it is the appropriate time to remind taxpayers and preparers of the various Affordable Care Act (ACA) estimators the Taxpayer Advocate Service (TAS) has developed and made available to the public. Whether the taxpayer is an individual or employer, we have several tools available to assist in estimating credits and payments related to the ACA. Keep in mind that they only provide estimates, rather than accurate calculations, to use as a guide in making decisions regarding the taxpayer’s tax situation.

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Financial Planning Considerations For Mixed Nationality Couples

Hugo Lesser, Tax Advisor

U.S. citizenship-based taxation has many planning repercussions for mixed-nationality families (i.e., where only one spouse is a U.S. citizen), and these are particularly acute when a mixed U.S./non-U.S. couple live and work outside of the U.S. and the family is subject to multiple countries’ tax rules.

How such a couple should proceed depends on a combination of financial and personal factors, including:

– Immigration and tax residence statuses (in the U.S. and elsewhere);
– Where the couple currently lives and where the couple plans to retire;
– The relative incomes of the couple (is one spouse sole breadwinner or are their earnings more evenly divided?);
– The relative family wealth the spouses come from; and
– Personal attitudes toward marital “sharing.”

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Testimony: Businessman Abroad Affected By FATCA

John Richardson, Tax Advisor

To Whom It May Concern:

Thank you for the opportunity to comment to the Committee. Under normal circumstances I would introduce myself however, given present circumstances, I cannot as my status as a US Person, is being reviewed by the State Department at my request to validate my relinquishing acts in the early 1970’s.

I am a Canadian citizen, registered as a Canadian born abroad at birth, in the United States while my Canadian parents completed their post graduate education in the United States.

If you are unaware, with the exception of the United States, it is not a good thing to be considered a US Person (a newly coined status) for tax purposes, if you live outside the U.S. It is not a good thing to have any U.S. indicia at all. Who am I?

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Tax Manager / Partnerships (Northern California)

The Tax Manager role requires partnership, S corporation, and high-net worth individual tax consulting/compliance experience and the skills to effectively diagnose clients’ needs in order to develop and implement solutions. Primary responsibilities involve providing tax compliance, tax accounting, tax research and planning for partnerships, S corporations and high-net worth individuals for sophisticated clientele. We will build upon your technical strengths in order to expand your expertise in other tax areas. Our firm builds well-rounded tax experts to serve a myriad of client needs which leads to continued professional growth. Our culture is to develop trusted tax advisors with sound judgement with the highest ethical standards in the profession. The Tax Manager/Partnerships will be responsible for a range of projects including:

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Whistleblower Awarded More Than a Million Dollars By The SEC

William Byrnes, Tax Advisor

The Securities and Exchange Commission announced that a whistleblower has earned an award of more than $1 million for providing the SEC with new information and substantial corroborating documentation of a securities law violation by a registered entity that impacted retail customers.

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Testimony: A Letter To Senators From An American Affected By FATCA

John Richardson, Tax Advisor

Dear Senators:

I wish to address a serious injustice that the United States government is perpetrating against millions of innocent law-abiding citizens and residents of countries around the world. Through the Foreign Account Tax Compliance Act (“FATCA”), the United States of America is violating the international human rights of persons who possess some degree of (often distant) US origin.

All of you and I share one thing in common: we were born in the USA. However, I was born to a Canadian father, who brought my family back to Canada when I was an infant. I am therefore a Canadian citizen from birth (“born abroad”) and I have lived essentially my entire life in Canada, only as a Canadian. I have never lived as an adult, studied, worked or earned income in the US.

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Tax Reform Framework: A Summary & Observations

Annette Nellen, Tax Advisor

On September 27, 2017, the Big 6 released their Tax Reform framework to guide the drafting of Tax Reform Legislation. Here is my summary and observations.

The plan also states President Trump’s Four Principles of Tax Reform:

  1. Simple, fair, easy to understand
  2. Give American works a pay raise.
  3. Make America a jobs market of the world
  4. Bring back trillions of dollars of unrepatriated earnings

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Should You Still Use a Foreign Asset Protection Trust? Maybe – A Very Qualified Maybe

Hale Stewart, Tax Advisor

Over the last few months, I’ve documented a series of cases where courts forced grantors of a foreign asset protection trusts to disgorge assets despite placing this fund into a “bulletproof” offshore structure. Those who continue using FAPTs offer the following rebuttals to the case law.Over the last few months, I’ve documented a series of cases where courts forced grantors of a foreign asset protection trusts to disgorge assets despite placing this fund into a “bulletproof” offshore structure. Those who continue using FAPTs offer the following rebuttals to the case law.

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Americans Abroad Need Your Help With Tax Reform – Listen To Their Stories

Kat Jennings, CEO

Congressional Tax Reform has the opportunity to end the U.S. practice of imposing direct taxation on people who live in other countries. The majority of Americans are totally unaware of the  issues surrounding Americans abroad. People are shocked to hear these stories. TaxConnections will continue to bring you these important stories of taxpayers around the world.

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Education Makes A Major Difference In A Corporate Tax Career

As a well-known expert in locating tax executives for major corporations around the world with a client list of Fortune 1000 companies, I know what companies search for in hiring for their corporate tax department. Having placed thousands of tax professionals over three decades, I know what it takes to make it to the top of tax organizations. The corporate organizations who retain us on tax searches have very high education expectations. Corporate executives expect their management teams to have advanced degrees and/or certifications and we know from experience having both is the best for your tax career. If you want to climb the corporate ladder in tax, you must have a graduate degree and or a CPA to stay competitive. What kind of education are you receiving today?

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Testimony: The Effects Of The Current Tax System On Americans Abroad

John Richardson, Tax Advisor

Good morning and thank you for the opportunity to speak with you today. My name is Marilyn Ginsburg. I will be 70 years old next month and I renounced my U.S. citizenship, with great regret, in my 69th year.

I was born in St. Louis, grew up in Denver, and moved to Canada when I was 26 years old. My husband and I left the United States in June, 1971, a month after we had both finished graduate school, I with a law degree and my husband with a PhD. in American history.We both obtained jobs teaching in our fields at a Canadian University. We assumed we would stay in Canada for a few interesting years, living in another country, and then return to hearth and home. One thing led to another and this never happened, and we have now lived in Canada for 44 years.

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