Pursuant to the requirements of the Balanced Budget and Emergency Deficit Control Act of 1985, as amended, refund payments issued to, and credit elect and refund offset transactions for, corporations claiming refundable prior year minimum tax liability, are subject to sequestration.
This means that refund payments and credit elect and refund offset transactions processed on or after Oct. 1, 2017, and on or before Sept. 30, 2018, will be reduced by the fiscal year 2018 6.6 percent sequestration rate, irrespective of when the IRS received the original or amended tax return.
The sequestration reduction rate will be applied unless and until a law is enacted that cancels or otherwise affects the sequester, at which time the sequestration reduction rate is subject to change.
In any successful family business there will likely come a time when descendants will want to take over the business from the older generation of owners. Usually, this will require that entities will need to be split into different business entities to accommodate both differences between the descendants (perhaps the descendants can’t cooperate with each other) or managing risk, so that high risk business can be separated from lower risk businesses and investments (construction business needs to be separated from investment assets such as stocks, bonds, annuity assets).
Canada Revenue Agency (CRA) has a number of dates and deadlines of importance to corporations. Failure to comply with these deadlines may raise a red flag with CRA, which in turn may trigger an audit.
When you spend years acquiring compensation data on corporate tax executives you learn a lot! TaxConnections conducts a compensation study every two years given the enormity of the project. This requires an extraordinary amount of effort to compile information, match up technical responsibilities for specialized tax roles, organize the information by geographical regions, and make sense of a wide range of equity programs. We conduct compensation studies in order to help corporate management teams attract the tax talent they need. These studies are not money-makers given the great deal of time it takes to prepare them. It is difficult to obtain salary information as people must trust you in order to get the real story! We must also organize it in a fashion that makes sense when you step out of the realm of base plus bonus and into the realm of equity and perks which are as vast as the sea. What you need to know is the real story behind corporate tax compensation if you want to successfully retain and keep the very best tax talent on the market..
The IRS, within the last year or so, has begun issuing a final Information Document Request that requests the taxpayer to agree to underlying facts relating to an issue under audit (the Facts IDR).
My general advice to clients is to not respond to the Facts IDR.
Giving a speech on tax reform whilst stumping for president in what is now seemingly a woebegone era of politics, Mitt Romney quipped this now seemingly famous sound bite personifying the greed of purported capitalism. According to US tax law, unfortunately he is right. Corporations are ‘treated’ like people.
Since this is how we live, when it comes to writing tax laws it seems a reasonable expectation that corporations behave as moral agents of society just like the rest of us. After all, they have their own decision structures and choices to make between rightness and wrongness, goodness and badness that are justified with reasons just like us. Read More
I am knee deep in another interesting file under dispute with our esteemed taxing authorities involving At-Risk Limitations. This is intended as the first of many posts on the topic as I navigate the shoals of a relatively complicated file that involves equipment leasing by a closely held C Corporation.
What are the At-Risk Rules? Read More
As lead tax executives have been searching for tax managers at the eight to twelve year range, many are asking “ Where is the talent?” I was talking to a close friend of mine by the name of Dr. Mishe Serra who earned her doctorate at Harvard. She is an expert on generational thinkers such as millennials who think very differently than today’s Baby Boomer generation. In particular, I discussed an executive search experiences very close to me and I sought her advice on my messaging in order to help this client attract elusive talent. What I learned from Dr. Serra I want to share with you because it is important to understand what is happening. Dr. Serra is an expert on the topic of millennials and we will be getting her insightful work in the hands of executives who want to be enlightened on hiring trends in the tax profession. Read More
(This is a continuation of a series of posts focused on Corporate Taxes. To read the first article, click here.)
Leading a corporate tax organization is a complex and sophisticated role which requires an extraordinary effort on the part of tax executives today. Corporate tax executives today are leading teams across multiple times zones with ongoing tax deadlines and a schedule of expectations by management that is never ending. The opportunity to work with corporate tax executives over three decades has taught me a lot about this highly educated group of professionals.
Why do you keep forming LLCs, partnerships or any kind of corporation when you’re not really ready to do business?
Then, you have these legal entities, with stringent tax filing responsibilities – and you do nothing.
A CFC is a foreign corporation where a U.S. shareholder owns “more than” 50% of the offshore company. Practitioners quickly noted the 50% ownership requirement and correctly deduced that, if a non-U.S. shareholder owned the remaining 50%, the foreign corporation could escape being a CFC.
The Colorado Department of Revenue has finally revised its guidelines in FYI Income 54 regarding people who do not live in Colorado but are partners and/or shareholders of partnerships and/or S corporations in Colorado, ensuring that pass-through entities pay Colorado income tax on their Colorado-source income. This Enrolled Agent says “About Time!”