TaxConnections


 
 

Complimentary Webinar On Friday, April 19, 2019: ASC 740 On Stock Comp, States And Uncertain Tax Benefits

Free ASC Webinar
COURSE: ASC 740 Intermediate Topics: Stock Comp, States and Uncertain Tax Benefits
DATE: Friday, April 19, 2019
TIME: 11:00AM EST/10:00AM CT/9:00AM MT/8:00AM PST
This course will discuss the intermediate ASC 740 topics such as stock compensation, states and uncertain tax benefits. It is a great course for practitioners new to ASC 740 or brushing up on their skills.
TaxConnections has invited internationally recognized tax provision expert Nick Frank to share what he has learned talking to Fortune 500 to Fortune 5000 clients about the corporate tax provision. He will also share what the tax auditors are saying about the corporate tax departments and their readiness on the tax provision. If you are not ready, you will want to attend this session to learn how to take a more simplified course of action with your corporate tax provision.

 

 

Citizenship And Worldwide Taxation: Citizenship As An Administrable Proxy For Domicile (Part 5)

Edward Zelinsky ( Part 5)
  1. Citizenship-Based Taxation and Benefits

Against the background established in the last three Parts, we can now assess the merits of the United States’ practice of taxing on the basis of citizenship, with a particular focus on the United States’ policy of taxing its nonresident citizens on their respective worldwide incomes and assets. In this Part, I evaluate citizenship-based taxation in terms of the benefits associated with U.S. citizenship. Governmentally furnished benefits are a traditional consideration for tax policy and, as we have seen, 130 is the rationale of Cook. However, upon examination, the benefits rationale for citizenship-based taxation proves unpersuasive, both in theory and in practice. The most significant civil and social benefits extended by the U.S. polity are tied to U.S. residence, not to U.S. citizenship.

The strongest benefits argument for citizenship-based taxation is one with which citizenship mavens are most uncomfortable, namely, the Tiebout/purchase characterization of citizenship as a public service purchased through tax payments. However, even that approach cannot be squared with the current system, which in practice charges different tax prices (often radically different tax prices) for the identical benefits of U.S. citizenship, depending upon the level and kinds of taxes assessed by the nation in which a U.S. citizen resides and earns his income.

Read More

Tax Reform Ideas To Reflect How Small Businesses Operate In The Modern World

Annette Nellen - Changes

The Tax Cuts and Jobs Act brought several improvements for small businesses, most notably, favorable accounting methods such as use of the cash method and not having to deal with the Unicap rules. The AICPA Tax Section recently posted a position paper noting 13 more changes that would further help modernize the Code to reflect how small businesses operate. Some of these would more completely simplify what Congress started with the TCJA.

For example, the TCJA increased the Section 179 expensing amount to $1 million, adjusted for inflation annually. But, despite the fact that intangibles are important to all sizes of businesses today (and for the past two decades), it only applies to tangible assets (and off-the-shelf software), not intangible assets, such as acquisition of a patent or domain name.

Read More

Consequences Of Failing To Resolve Your Tax Debt

Venar Ayar - Consequences
Are You Unable To Resolve Your Tax Debt?

Very few things in life are as stressful as owing the IRS money, especially if you do not have the funds to pay what you owe. “So what should I do?” You are probably wondering. Well, this should not be a complicated issue if you can get the services of a proficient tax defense attorney. Since what you do at this juncture will matter a lot, it is important that you do the right thing to avoid legal trouble. Here are a couple of things to keep in mind if you are unable to resolve your debt.

The Don’ts
1. Failing To File Returns

The first and most tempting mistake that most people make when they realize they are unable to pay their taxes is not filing returns at all. While this seems like a good idea, it will lead to more penalties. The IRS automatically places a 5% penalty each month up to 25% if you do not file your taxes. Furthermore, you will also be expected to pay interest on the total bill until it is paid in full.

Read More

IRS Issues Guidance Relating To Deferral of Gains For Investments In A Qualified Opportunity Fund

IRS - Opportunity Zones Update

The Internal Revenue Service issued guidance providing additional details about investment in qualified opportunity zones.

The proposed regulations allow the deferral of all or part of a gain that is invested into a Qualified Opportunity Fund (QO Fund) that would otherwise be includible in income. The gain is deferred until the investment is sold or exchanged or Dec. 31, 2026, whichever is earlier. If the investment is held for at least 10 years, investors may be able to permanently exclude gain from the sale or exchange of an investment in a QO Fund.

Qualified opportunity zone business property is tangible property used in a trade or business of the QO Fund if the property was purchased after Dec. 31, 2017. The guidance permits tangible property acquired after Dec. 31, 2017, under a market rate lease to qualify as “qualified opportunity zone business property” if during substantially all of the holding period of the property, substantially all of the use of the property was in a qualified opportunity zone.

Read More

National Taxpayer Advocate: Expanding Pay-As-You-Earn Tax Collection Could Bring Significant Benefits

Imagine it’s tax filing season. You’re dreading figuring out your tax liability this year, because in the last few years you’ve been earning sporadic capital gains and dividends that sometimes have led to a surprise tax bill at year-end. This year, though, is the first year that pay-as-you-earn (PAYE) tax collection has been expanded beyond wage income to cover additional types of earnings, causing your capital gains and dividends to be withheld at source, as well as some key deductions and credits, so that you don’t have to retrospectively reconcile your income, withholding, and deductions—all you need to do is fill out and file your Form 1040. There is no big bill, because withholding at source was applied on all of your income, and because it accounted in advance for the standard deduction and for the deduction you knew you would claim for student loan interest.

Read More

What Is A SWOT Analysis? It Positions Your Business!

A SWOT Analysis is a strategic planning tool to help you position your business within your market and your industry. The components that make up SWOT are: Strengths, Weaknesses, Opportunities and Threats. As a bonus, you can also throw in an additional T (SWOT-T), Trends. Here’s a short description of the SWOT components:

  • Strengths: What are your business’ strengths, relative to your direct competition and the market. These are internal. What do you sell, and how do you do it better than anybody else?
  • Weaknesses: What are your weaknesses versus the competition and overall market. Again, these are internal factors. Where do you need to make improvements, or at least have plans to fend off attacks against these weaknesses by competitors and a shifting market. Are you lacking resources to compete in certain areas?
  • Opportunities: These are long-term goals and are external to your business. Think sales and distribution channels, market sectors, etc.
  • Threats: The biggest threats to your survival come from the government, competitors, shifts in the industry, etc. Again, these are external. If you think of an internal threat, that’s most likely a weakness.
  • And sometimes Trends: What is the arc of your industry? A great case study is IBM, who has seen its products pivot from typewriters to personal computers to software to services to artificial intelligence. Where is your industry headed in the next ten years?

Read More

Citizenship And Worldwide Taxation: Citizenship As An Administrable Proxy For Domicile (Part 4)

Edward Zelinsky ( Part 4)
  1. Implementing Citizenship-Based Taxation

As a final preliminary to evaluating the United States’ citizenship-based taxation of individuals, we must explore the Code’s implementation of such taxation. Recall, in this context, that the Code currently prescribes three different income tax treatments for the foreign taxes paid by U.S. citizens and residents. Foreign income taxes levied against foreign-source income are fully creditable against U.S. income taxes to the extent such foreign taxes are equal to or less than the U.S. taxes assessed against such foreign-source income. 124 All foreign taxes paid in connection with trade, business, and investment activity are deductible for U.S. income tax purposes, as are foreign real property taxes. 125 Other foreign taxes, such as general sales taxes levied by foreign nations, are neither creditable nor deductible. 126 As a result of this disparate treatment of different foreign taxes, otherwise similarly situated U.S. citizens who reside abroad pay different U.S. taxes depending upon the types and amounts of the taxes levied by the countries in which they live and earn their incomes.

Read More

Employees’ Fringe Benefits After Tax Reform

Charles Woodson - Fringe Benefits

Tax reform made a lot of changes, some of which impacted employees’ fringe benefits. This article reviews the most frequently encountered fringe benefits, including those that were and were not impacted by tax changes. These changes can affect both a business’s bottom line and its employees’ deductions.

BENEFITS IMPACTED BY TAX REFORM

Qualified Transportation Fringe Benefits – Qualified transportation fringe benefits include parking, transit passes, commuter (van pool) transportation, and bicycle commuting.

  • Qualified parking – The tax-free fringe benefit for qualified parking is still available to employees and is capped at $265 per month for 2019, up from $260 in 2018.
  • Transit Passes – The tax-free fringe benefit for transit passes is also still available to employees, up to $265 per month for 2019, an increase from $260 in 2018.
  • Bicycle Commuting – Unfortunately, tax reform did away with the $20-per-month tax-free reimbursement for the cost of an employee commuting to work on a bicycle.
  • Commuting – Tax reform killed the monthly commuting fringe benefit (which was $260 in 2018) except when necessary for ensuring the safety of an employee. When allowed, the maximum amount is the same as the transit pass fringe benefit.

Read More

You Are Invited To TaxConnections YouTube Live Stream Event: What Is The Future Of Citizenship Based Taxation?

TaxConnections is privileged to announce the upcoming event on Citizenship Taxation will be hosted by William Byrnes of Texas A&M University, College Station, Texas. Our very distinguished speakers are John Richardson of Citizenship Solutions in Toronto, Canada and Edward Zelinsky of Cardozo School of Law in New York, New York. Mr. Zelinsky will speak in support of Citizenship Taxation and Mr. Richardson will speak out against Citizenship Taxation. Given the large number of expatriates who come to TaxConnections to discuss and seek answers to questions on FATCA and Citizenship Based Taxation, we are delighted to have these legal experts educate our expatriate and tax professional audience.

The Future of Citizenship Taxation

Citizenship Taxation: Is It Morally Justified Or Unjustified?

The future of Americans Abroad is greatly impacted by Citizenship Taxation. You are invited to a livestream YouTube event hosted by TaxConnections with two highly educated and distinguished lawyers discussing their position on Citizenship Taxation.

Date: Friday, May 17th
Time: 2:00PM EST/1:00PM CT/12:00PM MT/ 11:00AM PST
(World Time Zones)
Hosted By: TaxConnections – Meet The Experts
Moderator: William Byrnes
For Citizenship Taxation: Edward Zelinsky
Against Citizenship Taxation: John Richardson

Get A Great Education… It’s Free!

REQUEST YOUR FREE TICKET TO EVENT HERE

 

 

Citizenship And Worldwide Taxation: Citizenship As An Administrable Proxy For Domicile (Part 3)

Edward Zelinsky ( Part 3)
  1. Three Theories of Citizenship

In this Part, I identify three conceptions of U.S. citizenship that help to evaluate the propriety of citizenship-based taxation. Some commentators describe citizenship in terms different from those identified in these three models. 65 Whatever the value of these alternative conceptions of citizenship in other contexts, for the issue explored in this Article – the propriety of taxing on the basis of citizenship – these three models are the useful approaches to citizenship and the benefits defense of citizenship based taxation.

  1. The Minimalist Model

For Professor Bickel, a minimalist conception of U.S. citizenship both describes the reality of U.S. law and embodies a normatively desirable state of affairs: “Happily,” Professor Bickel wrote, “the concept of citizenship [*1304] plays only the most minimal role in the American constitutional scheme.” 66 Prior to the adoption of the post-Civil War Amendments, the U.S. Constitution “contained no definition of citizenship and precious few references to the concept altogether.” 67 Citing the First and Second Amendments, Professor Bickel noted that “the Bill of Rights throughout defines rights of people, not of citizens.” 68 Thus, “the original Constitution presented the edifying picture of a government that bestowed rights on people and persons, and held itself out as bound by certain standards of conduct in its relations with people and persons, not with some legal construct called citizen.” 69

Read More

You Are Invited To Complimentary Webinar On April 19, 2019: ASC 740 On Stock Comp, States And Uncertain Tax Benefits

Webinar ASC 740 Stock Options
COURSE: ASC 740 Intermediate Topics: Stock Comp, States and Uncertain Tax Benefits
DATE: Friday, April 19, 2019
TIME: 11:00AM EST/10:00AM CT/9:00AM MT/8:00AM PST
This course will discuss the intermediate ASC 740 topics such as stock compensation, states and uncertain tax benefits. It is a great course for practitioners new to ASC 740 or brushing up on their skills.
TaxConnections has invited internationally recognized tax provision expert Nick Frank to share what he has learned talking to Fortune 500 to Fortune 5000 clients about the corporate tax provision. He will also share what the tax auditors are saying about the corporate tax departments and their readiness on the tax provision. If you are not ready, you will want to attend this session to learn how to take a more simplified course of action with your corporate tax provision.

 

 

Meet Tax Experts At TaxConnections...