Brad Rolph is a Partner at Grant Thornton LLP in Toronto. He is one of Canada’s leading transfer pricing experts and was the first economist hired by any of the Big Four accounting firms in Canada to practice exclusively in the area of transfer pricing.
Tag Archive for tax education
Brian E. Andreoli is an international tax attorney and consultant in New York and focuses his practice on transfer pricing, international tax matters, and state tax matters. Mr. Andreoli has been a tax professional for more than 30 years, with experience in public, accounting, corporate (both foreign and domestic) law, and litigation.
Transfer Pricing Summit—Nationally Recognized Transfer Pricing Experts Teach You What You Need To Know Today!
Now that the United Kingdom has voted to leave the European Union, the question of how this will affect the global economy is one of the crucial issues for U.S. multinationals. The effects will have far reaching implications in transfer pricing and cross border activities. U.S. Multinationals are already considering the impact on and possible outcomes the vote will have on their businesses. In addition, to the direct trade effect, business investment around the globe is likely to be stifled somewhat due to the heightened uncertainty about the global implications of BREXIT and the tightening of financial conditions. Don’t miss this opportunity to learn from our tax experts, who will discuss and analyze the effects on transfer pricing and the global outlook on this decision, as well as, the OECD’s latest action plans under the BEPS (base erosion profit shifting) project and modifications to bilateral tax treaties.
One of the many exciting benefits of TaxConnections is the aggregation of the finest tax instructors in the industry to one global platform. With nearly 200 tax courses currently available on https://www.taxconnections.com/taxeducation with CPE or without CPE, and hundreds more in line to be uploaded on our tax education video platform, it is exciting to attract an increasing number of the very best tax educators around the world to TaxConnections. A group of experienced tax instructors are being assembled that are committed to promoting the very best tax education in the profession. TaxConnections is the catalyst bringing together an extraordinary group of tax educators in order to connect them to one worldwide platform.
During the year, we have interviewed many of tax instructors and are proud to introduce Read more
As the Founder and CEO of www.taxconnections.com, I want to welcome About.com Freelance Writer/Editor William Perez. William Perez is interested in interviewing members of TaxConnections on a wide variety of subject matters on tax. William joined TaxConnections and is eager to speak with and interview our members for media articles on tax topics. We encourage all of our members to reach out to William and send him a message at https://www.taxconnections.com/profile/William-Perez/12261048 with interesting stories on a wide range of subject matters.
We are fortunate in the TaxConnections community as we have tax experts from all over the world joining an interactive experience only available through membership in TaxConnections Worldwide Directory of Tax Professionals. Our members are leading the Read more
Who Decides Whether To Authorize A Taxpayer’s Certification For Transitional Treatment To The Streamlined Procedures?
Earlier this week, I spoke to an IRS Revenue Agent who shed some light on how the decision regarding transitional treatment is made for those taxpayers seeking to transition to the Streamlined Procedures from OVDP. Under the current procedures, the agent and his or her supervisor make the decision regarding transitional treatment, with involvement as necessary by the technical adviser. Practically speaking, the technical adviser does nothing more than “rubber stamp” the decision made by the examiner and the examiner’s manager.
While the process might seem straight-forward, it is not always seamless. That is where Streamlined Transition FAQ 8 comes into play. It provides some role for a central committee in those cases designated for central committee review. Unfortunately, no Read more
Disparity In Treatment of Taxpayers Who Qualify For Transitional Relief Is Casting A Shadow On The New Streamlined Procedures
Many tax practitioners have become disenchanted with the IRS’s treatment of those who are transitioning from OVDP to the Streamlined Procedures. What is the source of this disenchantment? Very simply, the IRS is denying the nonwillful certification in a disproportionately high number of cases.
To make matters worse, the process of denial is somewhat of an enigma. In OVDP cases, the IRS has more than just the certification. It also has the Offshore Voluntary Disclosure Letter and the accompanying documents that make up the final submission. According to many tax practitioners, if the certification causes the IRS to doubt the taxpayer’s claim that he was nonwillful, then its default position is to deny transitional relief. Read more
Often, a small business or start-up will utilize an S corporation election for their business. An S corporation is a corporation formed under a particular State’s incorporation laws (or an organization that has elected to be treated as a corporation for US income tax purposes). The corporation must be eligible to elect S corporation status and its shareholders must consent in writing on Form 2553 to have the corporation elect S corporation status. The Form 2553 must be filed with the Internal Revenue Service (IRS) on or before the 15th day of the 3rd month of the corporation’s tax year in order for the election to be effective as of the beginning of that tax year. If the corporation is on a calendar tax year, the Form 2553 must be filed on or before March 15th in order for the election to be effective for that tax year. Read more
Newly-revised versions of Publication 1, “Your Rights as a Taxpayer,” are now posted on IRS.gov in English, Spanish, Chinese, Korean, Russian and Vietnamese. By making this important publication available in multiple languages, the IRS hopes to increase the number of Americans who know and understand their rights under the tax law.
The Taxpayer Bill of Rights takes the multiple existing rights embedded in the tax code and groups them into 10 broad categories, making them easier to find and understand.
“We believe that these rights are critically important for people to know and understand, Read more
Australian “Significant Investor” Residence Visa Applicants Need To Consider Tax And Estate Planning Issues.
Australia’s 2012 “significant investor” residence visa scheme has attracted some 1,000 applicants who have committed to invest AUD4 billion in businesses or other complying investments. To date, the vast majority of applicants have been from Chinese nationals.
The scheme might have been expected to attract some interest from Russian entrepreneurs and investors. However, Australia’s personal tax rates may be a distraction (an effective maximum marginal rate of 49% currently applies to income in excess of AUD180,000 pa). Furthermore, the current geopolitical situation around Ukraine and the flight MH17 atrocity may now deter potential applicants who might be regarded as associates of the Russian leadership. Read more
Each year the IRS mails millions of notices. Here’s what you should do if you receive a notice from the IRS:
1. Don’t ignore it. You can respond to most IRS notices quickly and easily. And it’s important that you reply promptly.
2. IRS notices usually deal with a specific issue about your tax return or tax account. For example, it may say the IRS has corrected an error on your tax return. Or it may ask you for more information.
3. Read it carefully and follow the instructions about what you need to do. Read more
Part Two: Can the streamlined compliance procedures be used to correct defective returns that go back beyond the most recent three tax years?
Scenario Number 2: Failure to File A Tax Return in Tax Years Four Through Six
Adam is a U.S. citizen with an undisclosed offshore account. He moved to Switzerland in 2008 after taking a job with a Swiss consulting company and has lived there ever since. That same year Adam opened up a checking account at Grosser Schweizer Bank, a Swiss Bank.
Adam’s tax woes go back to 2008, when he relocated to Switzerland. He did not file any U.S. tax returns in 2008, 2009, and 2010. However, he has been fully compliant, at least as far as filing U.S. income tax returns go, since 2011. He has never filed an FBAR. Read more