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Tag Archive for Tax Law

The Trump Tax Reform — What A US Citizen In Israel Should Know

One of the pressing issues of President-elect Donald Trump’s campaign was his proposed tax reform. It is clear that not everything will be passed into law, and in fact changes were made over the course of the presidential race before arriving at the current proposal.  Of course, it is too early to know exactly what will change and by how much, but it is clear that some major changes will be made. With the backing of a Republican majority in both the House and Senate, it should not take long for these changes to happen. Furthermore, many of the changes are not significantly different than previously proposed tax reforms by some Congressmen, which should help ease their passage into law. Read more

Entity Classifications Under The New Tax Act

Welcome to 2018 and your new 2018 Tax Laws. If you are not aware, there is a new Tax Law that will affect all of you in our Professional care this year.

We know, understand and respect that each of your company’s DNA is unique. There are no simple answers to complex questions. Lately, the U.S. business media is abuzz with ideas and recommendations relative to the “best” corporate structure. While these are generic and generalized suggestions, some might have merit; there is little value without considering all the factors surrounding a business including, but not limited to: Read more

A Brief Overview of the Judicial Reasoning That Has Thwarted Foreign Asset Protection Trusts

Hale Stewart, Tax Advisor

As I have documented previously, there are several cases where courts have ruled against the grantors of a foreign asset protection trust, thereby nullifying the asset protection benefit. In this post, I want to briefly sum up the judicial reasoning used by the courts to thwart these trusts.

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Canadian Tax Help – Income Sprinkling Proposed Tax Changes

What are the proposed tax changes on sprinkling income using private corporations?

The Canadian government is proposing restrictions on income sprinkling to family members through dividends and capital gains. This targets private companies using shareholdings or a trust to split income among family members. Read more

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

Minnesota Sales Tax Exemption For Capital Equipment

In 2015, Minnesota sales & use tax law changed to provide taxpayers with an upfront sales tax exemption on eligible capital equipment purchases. To claim this Minnesota sales tax exemption at the time of purchase, taxpayers should present a fully executed Minnesota sales tax exemption certificate.  If Minnesota sales tax is paid at the time of purchase, taxpayers may still submit subsequent refund requests. Note that purchases of qualifying capital equipment made before July 1, 2015 are eligible for Minnesota sales tax refunds as well as long as they are within the 42-month open statute of limitations allowed under Minnesota’s sales & use tax law. Read more

Kanye West And Captive Insurance—There Is A Connection

My knowledge of popular culture is at best limited – and quickly declining. I know who Kanye West is. That’s it. But despite my less than literate knowledge of popular culture, this story from the Washington Post perfectly illustrates why he should have had a captive: Read more

U.S. Expat Mistakes: Part II

I have been on many online forums, message boards, and groups for U.S. citizen expats over the past few years. Most posts you see are ones with frantic U.S. citizens overwhelmed with U.S. tax rules & regulations they have to keep up with. This, in addition to keeping up with their resident country’s tax laws, must drive one crazy. These forums provide quick answers; no wonder they are so popular! Read more

Determining Tax Residency In The United States

John Richardson

The advent of the OECD Common Reporting Standard (CRS) has illuminated the issue of tax residency and the desire of people to become tax residents of more tax favorable jurisdictions. It has become critically important for people to understand what is meant by tax residency. It is important that people understand how tax residency is determined and the questions that must be asked in determining tax residence. Tax residency is NOT necessarily determined by physical presence.

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Italian Supreme Court Ruling On Beneficial Ownership

Marco Rossi

With its ruling n. 27113/2016 issued on December 28, 2016, the Italian Supreme Court interpreted and applied the beneficial ownership provision of article 10 of the tax treaty between Italy and France, for the purpose of determining whether a French holding company, wholly owned by a U.S. corporation, was entitled to the imputed credit granted under that treaty in respect of dividends received from an Italian subsidiary.

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Is Your Refund Part Of The $1B Unclaimed?

Barry Fowler

If you haven’t filed your 2013 taxes you could have a refund among the more than $1 billion that the IRS has stated is unclaimed.

That’s right. Just recently the IRS stated that it has more than $1 billion worth of unclaimed tax refunds for people who have not filed their 2013 taxes. They indicate that there are roughly 1 million people who have not filed and have not claimed their refunds.

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ACA Replace Proposal & Insurance Company Compensation

Annette Nellen

The tax law is difficult to understand due to its numerous special rules. This is apparent on just about every news show about the House Republican/President Trump’s bill to replace/repair the Affordable Care Act (aka Obamacare). Last night, I saw a bit of a CNN town hall with HHS Secretary Tom Price. Questions were raised about the bill providing significant benefits to high income/wealthy individuals. In addition to repeal of the Net Investment Income Tax (Section 1411), a comment was made by the CNN reporter about repealing the ACA rule regarding a compensation limit on high compensation of health insurance companies.

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