Access Leading Tax Experts And Technology
In Our Global Digital Marketplace

Please enter your input in search

Archive for TaxConnections

TaxConnections Virtual Tax Summit – Tax Professionals AND Business Owners Invited To November 12, 2021 Event

Virtual Tax Summit Free Ticket

In a world of rapid change, engaging with and learning from other professionals is key to the success of every business organization. Having a support team of trusted professionals provides valuable expertise vital to the success of every organization.

On Friday, November 12, 2021, TaxConnections hosts the Virtual Tax Summit with leading tax advisors who share their expertise with tax colleagues and small to medium-sized business owners. The benefit of attending this online event is you will learn three ground-breaking innovations being quietly deployed that support the growth of small to medium-size enterprises.

The Virtual Tax Summit is uniquely different from other events. Tax Professionals AND Entrepreneurs are invited to participate in this online experience. Our Speakers bring valuable expertise gained through first-hand experiences with entrepreneurs who have faced a wide range of issues while growing their businesses. Scaling a company to grow requires constantly improving business processes and strategy to advance to the next level.

Register Today For Free Ticket To Virtual Tax Summit

(Selected Sessions Provide CPE For Tax Professionals)

Contact if interested in sponsorship.

Biden Administration Overriding Tax Treaties. Does This Mean Existing Treaties Are Worthless?

Biden Administration Overriding Tax Treaties

(The above tweet was a response to a recent article in the Financial Post.)


This post is a comment on yesterday’s Tax Connections post “Ranking Members Warn Against Bypassing Treaty Process“. As is well known the United States has been hugely supportive of the International Tax Reforms known as “Pillar 1” (granting source country taxing rights to certain profits earned by certain multinationals) and “Pillar 2” (establishing a global minimum tax on the profits of certain multinationals). Apparently 136 of 140 countries have agreed to the two Pillars of international tax reform. The agreement signified a country’s commitment to make the necessary domestic changes to meet its international obligations.

Read more

Deductibility Of Trucks, Cars, Retirement Contributions, Unreimbursed Employee And Demolitions Expenses

Deductability Of Trucks, Cars, Retirement Contributions, Unreimbursed Employee And Demolitions Expenses

Freeman Law’s “The Tax Court in Brief” covers  substantive Tax Court opinions, providing a weekly brief of its decisions in clear, concise prose.

Daniel Omar Parker and Chantrell Antoine Parker v. Comm’r, No. 13231-19, T.C. Memo 2021-111 | September 23, 2021 | Lauber | Dkt. No. 13231-19

Short Summary:  This case analyzes the availability of certain deductions of the taxpayer, namely:  (1) Car and truck expenses; (2) Retirement contributions; (3) Certain unreimbursed employee business expenses claimed as itemized deductions on Schedule A; and (4) the cost of demolishing a structure.

Key Issues:

  • The deductibility of various expenditures.

Facts and Primary Holdings

Read more

U.S. Congress Committee On Ways And Means: Chairman Neal’s Opening Statement Relating To Infrastructure Financing

Infrastructure Bill

The Committee on Ways and Means is the oldest committee of the United States Congress, and is the chief tax-writing committee in the House of Representatives.

The Committee derives a large share of its jurisdiction from Article I, Section VII of the U.S. Constitution which declares, “All Bills for raising Revenue shall originate in the House of Representatives.”

Pursuant to notice, we will now turn to consideration of our Budget Reconciliation Legislative recommendations relating to a variety of tax and health measures. This committee print is by far the most far reaching and voluminous of the recommendations we have considered during this reconciliation process.  I am quite certain there will be spirited debate over the next two days that is commensurate with the historic magnitude of what we are undertaking.  Put simply, these are investments that promise to shape the lives of Americans for the better for generations to come.
Read more

A Landscape PAINting Of The Effects Of U.S. Citizenship-Taxation On U.S. Citizens Living Outside The U.S.

A Landscape PAINting Of The Effects Of U.S. Citizenship-Taxation On U.S. Citizens Living Outside The U.S.


Read more

What Is Required To Run A Foreign Business In Korea? (Part I In Series)

What Is Required To Run A Foreign Business In Korea?

1. From A Legal Aspect Foreign companies are required to have any one of following legal entities in Korea

A. Set-up Of Foreign Subsidiaries – Wholly Owned Or Joint Venture

(1) The subsidiaries shall be established pursuant to the provision of Foreign Investment Promotion Act and Commercial Code of Korea and the establishment be registered with the court based on separate document, Topic 1-1, and obtaining court registration certificate after registration)

(2) Application for Certificate of Foreign Invested Enterprise proving foreign investment with following documents attached.

a. Application for the Certificate

b. Court registration certificate of Korean subsidiary

Read more

The Effects Of Increased Funding For The IRS

U.S. Congressional Budget Office

Last month, the Congressional Budget Office published An Analysis of Certain Proposals in the President’s 2022 Budget. Since then, CBO has completed its analysis of another proposal in the President’s budget, an increase in spending for the Internal Revenue Service’s (IRS’s) enforcement activities. CBO estimates that portions of the Administration’s proposal to increase funding for the IRS by $80 billion over the 2022–2031 period would increase revenues by approximately $200 billion over those 10 years. That estimate does not include changes in revenues resulting from portions of the proposal that involve new information-reporting requirements and other changes to the tax code; those changes are estimated by the staff of the Joint Committee on Taxation (JCT).

The Proposal

The Administration proposes funding for the IRS that is $80 billion greater over 10 years than the amounts in CBO’s July 2021 baseline projections (which reflect the assumption that current laws generally do not change). Two types of funding would be provided: discretionary appropriations, which would mainly be used for enforcement activities; and mandatory funding, which would be used for a variety of activities (not only enforcement but also operations support, business-systems modernization, and taxpayer services).

Read more

What You Need To Know About The Taxation Of Streaming Services

What You Need To Know About The Taxation Of Streaming Services

When it comes time to relax with your favorite show, where do you go to find it? Over the last decade, more and more people have made the choice to look online and utilize streaming services like Netflix and Hulu instead of depending on traditional cable or satellite TV.

This trend is in line with digital transitions in many industries, and like those other industries, it presents new tax challenges for regulatory agencies and streaming companies alike.

In this article, we’ll share the brief history of streaming taxes, where we are today and our predictions for the future.

An Overview Of Streaming Taxes

As the most famous of the streaming services, Netflix paved the way for those that followed in its wake. First offering its “Watch Now” video on demand service in 2007, Netflix has more than 208 million paying subscribers, with 74.4 million of those in the U.S. and Canada.

Read more

Government’s Latest Move On Cryptocurrency Taxation

Government’s Latest Move On Cryptocurrency Taxation

$1.1 Trillion Infrastructure Bill Is Government’s Latest Move On Cryptocurrency Taxation

The proposed infrastructure bill valued at just over $1 Trillion over a 5-year period has recently made its way through the senate1. The Bipartisan Infrastructure Deal is monumental and would make some of the largest federal investments in public transit, clean drinking water, bridges, and electrical vehicle infrastructure in the history of the United States. Unfortunately, these things are never as simple as they seem. Although the bill had bipartisan support with a voting of 67-32, it is still not fully out of the woods yet. The bill itself is over 2,000 pages in length and includes funding for some of the projects mentioned as well as; highways, airports, cyber defense, and climate change just to name a few. This deal comes as the democrats and the Biden administration ready a much larger $3.5 trillion package that is currently being considered under budget rules which would only need 51 senators with Vice President Kamala Harris able to break a potential tie.

Key to Infrastructure Deal and New Stimulus is the Taxation of Cryptocurrency

Read more

Tax Issue Or Human Rights Issue? Maehr Reminds Us To Consider The Broader Implications Of Tax

Tax Issue Or Human Rights Issue? Maehr Reminds Us To Consider The Broader Implications Of Tax

Tax Connections is a tremendous resource that focuses on tax issues. It’s important to remember that behind every tax issue there is a real person. That real person is often dealing with an issue that extends far beyond the concerns of that individual. The recent 10th Circuit decision in Maehr is a prime example. The Maehr decision was discussed in a comprehensive post at Tax Connections. That particular post focussed on only the narrow tax aspect – specifically the passport revocation section found in the Internal Revenue Code.

This post is for the purpose of illuminating the impact that (what appears to be) a tax decision can have on fundament rights in general. To put it simply: the 10th Circuit decision in Maeher stands for the legal proposition that Americans are NOT free to leave the United States without the permission of the US Government.

Read more

US Tax Guide For Foreign Nationals Working Or Investing In The United States

US Tax Guide For Foreign Nationals Working Or Investing In The United States

This guide is dedicated to helping you comply with US tax laws if you are a foreign national (resident or nonresident alien) working or investing in the US.  We take you through the substantial presence test and show you how to determine your US tax resident status. Regardless of your visa status, you will learn about the US resident tests for tax purposes, which are different than for immigration purposes.

If you are a nonresident alien, investing in US real estate or other US business activities from your home country, we give you an overview of deductions and credits available on Form 1040NR. We explain your tax filing options. For example, in the year of arrival, you might qualifiy for a dual status, resident or nonresident tax return.

You will also learn the more complex tax rules that apply if you are an F1 or J1 visa holder. Then we give you an overview of tax treaty benefits, which are particularly useful for F1 and J1 visa holders. Finally, you will learn about ITIN requirements, state tax requirements and social security and Medicare tax withholding rules.

For most Americans, completing their tax return is a confusing and frustrating exercise. We can only imagine how ominous the task must seem for you, a foreign visitor. Hopefully the information you find here will make the job easier.

Form 1040NR Filing Requirements

Who Needs to File a US Tax Return?


Read more

TaxConnections Virtual Tax Summit: Last Call For Speakers

TaxConnections Virtual tax Summit Call For Speakers

TaxConnections Virtual Tax Summit will be held on Friday, November 12, 2021. The focus of the event will be tax experts helping small to medium size businesses and the tax advisors supporting them. We have identified Speaker Sponsors who are committed to helping small to medium size businesses grow and they will be sharing their strategies with our attendees.

TaxConnections Virtual Tax Summit will post our registration page soon to provide 1000 VIP Complimentary Tickets to tax advisors and business owners. Our focus is bringing tax advisors and business owners together at this important online event. TaxConnections Members will be the first to receive the Complimentary VIP Passes into the Virtual Tax Summit. Selected presentors during the Virtual Tax Summit will provide CPE to tax professionals.

Our Virtual Tax Summit Agenda currently has Speaker Sponsors covering Indirect Taxes and Tax Processes (Siemens Corporation); and State and Local Tax issues (Ducharme, McMillen & Associates) among others.

If you would like to be a Speaker Sponsor and have topics of interest to small to medium size business owners and tax professionals please contact by email to arrange a time to discuss your presentation opportunity.