TaxConnections


 

No Refunds For OVDP Participants Without Filed Return

Ephraim Moss

In a recently published Chief Counsel Advice, the IRS chief counsel’s office offered advice to taxpayers participating in its amnesty programs regarding the issue of whether refunds for past overpayments of tax can be used to offset additional taxes or penalties triggered under the program.

Before we get to the advice, let’s first review the amnesty programs that could potentially be affected by the conclusions made in the published advice.

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Compensation For Corporate Tax Executives—Friday, May 19th

Kat Jennings

You are cordially invited to a webinar on Compensation For Corporate Tax Executives. After spending a great deal of time this past year surveying tax executives on compensation, I am confident the information delivered during this webinar will be valuable to you.

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Tax Treaty Tiebreaker And Reporting: Forms 8938, 8621, 5471

John Richardson

Previously, we have look at the tax treaty tiebreaker and how it relates to taxation of Subpart F and PFIC income as well as eligibility for streamlined offshore procedures. This is another in a series of posts on the tax treaty tiebreaker (which is a standard provision in most U.S. tax treaties).

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The OVDP Program May End After 2017

Ron Marini

U.S. taxpayers who have foreign bank and/or financial accounts should be watching the clock. The window to voluntarily report foreign accounts in order to mitigate IRS penalties may be ending after 2017.

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You Thought Your Information Was Safe With The IRS

Barry Fowler

It looks as if taxpayers have to be wary and skeptical even when they send their personal information to the IRS. This government agency is supposed to be trusted with our personal information. Especially at a time when criminals are posing as IRS agents over the telephone, through email, through our employers human resources departments and through schools you would think the IRS itself would be safe. But no!

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Employee Fidelity Coverage – A Personal Account

Hale Stewart

I recently had a client place family heirlooms with a service. Unfortunately, these were stolen while in the service’s possession. The items were not only valuable from a monetary perspective but also in a sentimental sense. And, it’s highly doubtful they will ever be found.

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VP Of Tax/Tax Partner – Want An Exciting Career Change?

Kat Jennings

TaxConnections has developed innovative technology in bringing Virtual Tax Offices into the profession. We are searching for bright Tax Partners/Tax Directors who want to leave public accounting, a law firm or corporation to leverage their career equity. We have worked tirelessly to build a media platform to drive new business to tax professionals at TaxConnections.

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Are You Hiding Assets In The BVI?

Ron Marini

The British Virgin Islands’ Government has signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK & BVI law enforcement for taxation rulings.

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California Software TTA Exemption

Aaron Giles

In 1993, the California legislature enacted a sales tax exemption for technology transfer agreements (“TTA”) relating to the transfer of intellectual property, but has never really honored that exemption until the 2011 Nortel court ruling. Now in 2017, California says it is nearly ready to begin issuing refund checks.

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Business Intelligence: Practice Ignition For Tax Engagements

Practice Ignition is designed to assist accountants manage their engagement letters, client payments and raise invoices. For you as a business owner, another major advantage of the software is also the ability to process your tax engagements (in addition to your normal engagements). There are three key benefits to this:

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Tax Job: Tax Manager/ Partnerships For Northern California Firm

tax jobs, tax manager, north california

Kat Jennings, TaxConnections CEO and internationally recognized tax search consultant, has worked with many firms over the years. One of her clients is an East Bay Area boutique tax practice with former Big Four Tax Partners and has grown to around a 50-person tax practice. They offer a culture of support, respect, flexibility, and opportunity that is refreshing to experience these days.

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Tax Treaty Tiebreaker And Taxation Of Subpart F And PFIC

John Richardson

Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on:

A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?)

B. His/her status under Title 26 (will he expatriate himself under Internal Revenue Code S. 7701(b)) and subject himself to the S. 877A “Exit Tax” provisions?

Now, on to the post

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