Archive for April 28, 2014

51 FATCA Agreements And Growing!

On Friday, April 18, 2014, we posted “FATCA Picking Up Momentum And U.S. Gives Foreign Banks More Time to Register”, where we discussed the Internal Revenue Service’s Announcement 2014-17 which provides that countries that have FATCA agreements “in substance” with the United States will be seen as complying with the law, even if the agreements are not finalized by December 31, 2014.

This announcement increased to 48 from 26 the number of countries that have “intergovernmental agreements” (IGAs) with the United States, which allow a country’s financial institutions to comply with FATCA via their domestic regulators. This would include Brazil, South Korea and South Africa, among other countries, who are in the process of negotiating IGA with the US. Read More

Written by | Posted in FATCA

Money Laundering: Who Has Dirty Money?

“Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit activities.”…U.S. Department of Treasury Website

Law enforcement and financial regulators everywhere are on the lookout for money laundering. Big corporations and financial institutions hire compliance experts, and those experts cooperate fully rather than face huge fines and penalties.

While money laundering is a single process, it does have three stages:

1. The Placement Stage

This is where the “dirty” money or cash proceeds of criminal activity first enter the Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

Taxpayers Rights When Audited By Tax Authorities In South Africa (Chapter 1 – 1.5)

Posted in sections, this is my Doctoral Thesis on taxpayers rights when audited by the tax authorities in South Africa – equally applicable to many English-based law systems in Africa and abroad (eg. India). This will be of particular use to any tax practitioners doing work in Africa and in other English-based legal systems around the world.

Analysis Of Challenging The Commissioner’s Discretionary Powers In Auditing Taxpayers under The Constitution Of The Republic of South Africa

1.5 THEORETICAL FRAMEWORK AND HOW THE METHODOLOGIES EMPLOYED WILL ADDRESS THE RESEARCH QUESTION

The present research analyses and interprets the Constitution, together with relevant Read More

Written by | Posted in Africa • Audit

The IRS Provides Options for Taxpayers Who Owe Tax After April 15!

Here are some options to consider, even if you can’t pay the full amount right now:

• Borrow the money. If you don’t have the money to pay all your taxes now, then you may want to get a loan from a bank or other source. The interest rate may be lower than the interest and penalties the IRS charges on late taxes. You also may be able to borrow against your assets or sell them to raise cash.

• Make an Online Payment Agreement. If you are unable to pay in full, then consider paying over time.

◦ If you owe $50,000 or less, you can apply for an installment agreement. You may Read More

Written by | Posted in IRS

Tax Professionals – Learn How To Boost Yourself To The Top of The Search Engines

We researched what was happening behind the scenes for tax professionals who wanted more business! We discovered their reputations were buried on pages in the search engines and developed a solution that would enable tax professionals to jump to the forefront and give them a huge SEO Booster Shot. We are going to show you what is happening and prove to you how you can correct it TODAY!

• Consumers go online to search “ Find a Tax Advisor” and what do they see?

◊ 57,200,000 Pages of Choices For Find A Tax Advisor
◊ 98,100,000 Pages of Choices For Find A Tax Lawyer
◊ 18,500,000 Pages of Choices For Find A Tax CPA Read More

Written by | Posted in TaxConnections

IRS Updates FATCA User Guide

The Internal Revenue Service has updated Publication 5118 – Foreign Account Tax Compliance Act (FATCA) User Guide (Rev. December 2013) to reflect changes since its initial publication in the summer of 2013.

The User Guide is over 100 pages and provides instructions for completing the registration process online, including the information required, how registration will vary depending on the type of financial institution, and step-by-step guidance for answering each question.

1. The User Guide provides a list of entities that are eligible to register, on behalf of themselves and their branches, and the purposes of such registration (page 8). Read More

Written by | Posted in FATCA • IRS

Taxpayers Rights When Audited By Tax Authorities In South Africa (Chapter 1 – 1.4)

Posted in sections, this is my Doctoral Thesis on taxpayers rights when audited by the tax authorities in South Africa – equally applicable to many English-based law systems in Africa and abroad (eg. India). This will be of particular use to any tax practitioners doing work in Africa and in other English-based legal systems around the world.

Analysis Of Challenging The Commissioner’s Discretionary Powers In Auditing Taxpayers under The Constitution Of The Republic of South Africa

1.4 RESEARCH OBJECTIVES, METHODOLOGIES AND POTENTIAL FINDINGS

1.4.1 Research Objectives

The primary objective of the research done in this dissertation is to critically analyse Read More

Written by | Posted in Africa • Audit

Introduction To Section 482 And International Financial Centers

Introduction

As an introduction to International Financial Centers and the pricing concepts between structures of entities, an integration of international law principles and taxation concepts is desirable. This is the essence and difficulty of understanding Financial Centers Offshore. It requires a melding of international financial law, international civil and criminal law, and international taxation rules. It is the bifurcation of these disciplines that makes International Financial Centers so elusive.

The foundation to a discussion of entity structure concepts is melding the taxation rules peculiar to foreign corporate entities; controlled entity rules, source of income Read More

Written by | Posted in Corporate • International

Electing To Treat A Nonresident Spouse As A U.S. Resident

If you meet the conditions of the substantial presence test, you are considered to be a U.S. resident for U.S. International tax purposes.  If you qualify as a U.S. resident under the substantial presence test, you may be able to have your nonresident spouse treated as a U.S. resident for tax purposes even if your spouse does not qualify under the substantial presence test.

What are the Benefits of Treating a Nonresident Spouse as a Resident?

If you elect to treat your nonresident spouse as a resident for U.S. taxation purposes, in the year that you make that election, both you and your nonresident spouse will be taxed on your worldwide income.  IRS – Nonresident Spouse Treated as a Resident.  In Read More

Written by | Posted in International • IRS

The Independent Contractor Ranks Are Growing

The number of workers identifying themselves as “independent contractors” is growing in the United States. In 2005 the U.S. Bureau of Labor Statistics determined that the number of independent contractors rose from 6.4% of the workforce in 2001 to 27.4% of the workforce by 2005. In 2010, Navigant Economics claimed the following:

“More than 10 million workers, comprising 7.4 percent of the U.S. workforce, are classified by the Bureau of Labor Statistics as independent contractors, and another 4 million work in alternative work arrangements in which they may be legally classified as independent contractors for one or more purposes. Alternative workers in 2010 will account for approximately $626 billion in personal income, or about one in every eight dollars earned in the U.S.” Read More

Written by | Posted in Federal • Individual • Tax Provision/Tax Reporting

Taxpayers Rights When Audited By Tax Authorities In South Africa (Chapter 1 – 1.3)

Posted in sections, this is my Doctoral Thesis on taxpayers rights when audited by the tax authorities in South Africa – equally applicable to many English-based law systems in Africa and abroad (eg. India). This will be of particular use to any tax practitioners doing work in Africa and in other English-based legal systems around the world.

Analysis Of Challenging The Commissioner’s Discretionary Powers In Auditing Taxpayers under The Constitution Of The Republic of South Africa

1.3 RESEARCH QUESTIONS AND HYPOTHESIS

The aim of this dissertation is to critically evaluate SARS information gathering powers from the following two perspectives: Read More

Written by | Posted in Africa • Audit

Manufacturing Exemption From Sales And Use Tax

California State Board of Equalization Manufacturing Exemption from Sales and Use Tax is Scheduled to Begin in July, 2014

A law created by Governor Brown’s 2013 Economic Development Initiative allows certain businesses in manufacturing or in the fields of biotechnology or physical, engineering, and life sciences to purchase or lease manufacturing or research and development equipment at a reduced sales and use tax rate for purchases occurring on or after July 1, 2014. (See Assembly Bill 93 (Stats. 2013, Ch. 69) and Senate Bill 90 (Stats. 2013, Ch. 70); and Revenue & Taxation Code section 6377.1.) The California State Board of Equalization (BOE) will be the agency overseeing and implementing this manufacturing exemption. Read More

Written by | Posted in Sales/Use Tax
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