TaxConnections


 

Americans Abroad And IRS ‘Amnesty’ Offers In OVDP

In an earlier post, I explained why the Canada Revenue Agency assisted the IRS in collecting a penalty on a Canadian resident. The bottom line was that he was presumably NOT a Canadian citizen and therefore did NOT have the benefits of the tax treaty. This post is to explain where the penalty came from in the first place.

It has been widely reported that a U.S. citizen residing in Toronto, Canada since 1971, paid a $133,000 U.S. dollar penalty for failing to file IRS forms disclosing that he was running a business through a Canadian corporation. How did this fly get caught in the spider’s web? Read More

At-Risk Limitations (IRC § 465) Part 1

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

Job Opportunity – Tax Manager/ Partnerships – Northern 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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Understanding U.S. Federal Taxes For American Expats

The USA is almost unique in taxing U.S. citizens even when they live abroad. This means that expats who earn over $10,000 ($10,300 for 2016, to be precise, or just $400 of self-employment income) are required to file a U.S. federal tax return, regardless of where their income originates, or whether they are also paying taxes elsewhere.

While expats still have to pay any U.S. tax they may owe by April 15th, they have until June 15th to file, with a further extension available on request to October 15th. Read More

TEI-San Jose State University High Tech Institute Conference Larry Langdon – An Interview With A Tax Luminary

This interview is the second in a series of interviews conducted in partnership with TEI-San Jose State University High Tech Institute. Silicon Valley has an amazing community of tax professionals and this series is one I have personally wanted to do for quite some time on Silicon Valley tax luminaries. Annette Nellen has done an amazing job building this conference to national acclaim. (Please refer to my previous interview of Annette Nellen which kicked off the special interview series on tax luminaries.) Read More

Fiscal Year 2018 Per Diem Rates

The IRS permits taxpayers to use general predefined rates to substantiate business expenses under Internal Revenue Code Sec. 274(d) for lodging, meals, and incidental expenses incurred while traveling away from home for business purposes.

The General Services Administration (GSA) released the federal domestic per diem rates for periods effective from 10/1/17 through 9/30/18 (aka fiscal year 2018). Read More

What To Do When You Receive An Audit Letter

Summer is typically when the IRS sends out notices and audit letters, so if you’ve received one, remember, first and foremost, don’t freak out.

Don’t panic!

After all, it’s just a piece of paper sent to you from the IRS. While the IRS can be scary, if you are a law-abiding taxpayer, I assure you even if you end up getting audited it’s not as scary as it seems. Read More

Global Forum Publishes Ratings On Tax Transparency

The Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) published the first 10 outcomes of a new and enhanced peer review process aimed at assessing compliance with international standards for the exchange of information on request between tax authorities.

The new round of peer reviews – launched in mid-2016 – follows a six-year process during which the Global Forum assessed the legal and regulatory framework for information exchange (Phase 1) as well as the actual practices and procedures (Phase 2) in 119 jurisdictions worldwide.

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Canadian Tax FAQs – Proposed Canadian Tax Changes

What are the proposed tax changes to private corporations that the Canadian government made in July 2017 and what do these changes mean for my company?

On July 18, 2017, the Canadian government proposed tax changes in an effort to remove tax advantages that small business owners have and address aggressive tax planning strategies involving the use of private corporations. These proposed changes are open for discussion until October 2, 2017, before being formally submitted for legislation. Read More

Federal Tax Reform And Intangibles

Annette Nellen

Federal tax reform discussions have included writing off all business assets (other than land) at acquisition. In contrast, some have suggested increasing the Section 179 expensing amount which covers tangible assets. Some reform proposals have suggested lengthening depreciable lives for tangibles and intangibles. Proposals are obviously quite varied. I think that is primarily due to two factors: (1) no agreed upon goal for tax reform, and (2) focus on hitting a certain revenue target to allow for lower rates in a revenue neutral manner. Read More

The Canada-U.S. Tax Treaty Does Not Protect From Tax Liability

Dewees 1: The Canada-U.S. tax treaty does NOT protect Canadians from U.S. tax liability but does mean that Canada will NOT assist the U.S. in collection!

There are certainly benefits to being a Canadian citizens. Perhaps Canadian citizenship is the most important line of defense against the confiscation that is OVDP. Read More

All That You Wanted to Know About Form 706NA – Part I

Deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets. Also, many foreigners owning property or assets in the United States are in violation of 706-NA filing requirements because of a number of misunderstandings. The basic rule is pretty clear-if a foreign decedent has assets in the United States with a gross value in excess of $60,000, the estate is supposed to file a tax return with the Internal Revenue Service.  Read More

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