Why do some Canadians wish to have a U.S. Social Security number?
Many Canadians are in the process of coming into U.S. tax compliance. One might ask: Why would a Canadian citizen residing in Canada wish to come into U.S tax compliance?
There are two reasons why Canadian citizen/residents file U.S. tax returns:
Today’s blog post is yet another interview that provides valuable insight from Willard (Bill) Yates, who recently retired from the Office of Associate Chief Counsel (International) (ACCI), Internal Revenue Service after 31 years of service. During his tenure as a Chief Counsel Attorney, Bill was the recipient of 10 awards, including the Albert Gallatin Award, Treasury’s highest career service award. The Gallatin is awarded only to select federal employees who served twenty or more years in the Department and whose record reflects fidelity to duty. Bill received the Gallatin award for his work throughout his IRS career, including his work on implementation of some of the compliance requirements of FATCA – the Foreign Account Tax Compliance Act. Read More
Foreign Financial Institutions are not getting the best of Christmas presents this year. Instead of getting sugar plums in their stockings, they are getting FATCA and GIIN!
By brief background, under the Foreign Account Tax Compliance Act, (FATCA), foreign financial institutions (FFIs) and non-financial foreign entities (NFFEs) must agree to verification and due diligence procedures – meaning they must be on the look-out for customers, owners or beneficiaries evidencing any “US indicia”. They must identify and report directly to the United States Internal Revenue Service (IRS) or their own government via an intergovernmental agreement (IGA), information on US account holders/owners. They must look through their customers and counterparties’ ownership to find “substantial United States owners” (generally, more than 10 percent ownership). Read More
IntroductionRecently there has been a flurry of activity with respect to International Financial Centers and their standing and obligations concerning the disclosure of their financial clients and records. This text will direct itself to the fundamentals of the tools that have traditionally been utilized to monitor, sensible regulation, reasonable supervisory monitoring, and appropriate national enforcement.
This will be presented in segments of regulation, the tools of enforcement of those regulations, and taxpayer defenses to enforcement. A main purpose is to establish an understanding of principles that will give a more meaningful understanding of the various unilateral agreements between the United States and various countries regarding business activities, including the use of anonymous banking facilities.
The apparatus of the United States government in implementing a supervisory role of international transactions emphasizes the functions of the Treasury Department and its collection agency, the Internal Revenue Service (hereinafter the Service). The functions can be divided into record keeping requirements imposed on taxpayers, examination authority of the Service in the monitoring phase of international activity, and enforcement used to compel compliance. Read More
Investment income may be subject to refundable tax of 26.67% of investment income. Portfolio dividends may be subject to Part IV tax of 33.33%. Part IV tax is added to the refundable dividend tax account. Investment income includes net rental income, taxable capital gains.
For non-CCPCs, the tax rate is 26.5% on investment and active business income.
| Active business income up to $500K | Active business income exceeding $500K | Investment income |
| 15.50% | 26.50% | 46.17% |
Louisiana Governor Bobby Jindal has signed into law a bill that disqualifies many retailers from participating in the state’s Enterprise Zone Program (“Program”) and makes other changes to the Program’s required employment criteria. House Bill 571 (“H.B. 571”) became effective immediately when Governor Jindal signed it on Friday, June 21, 2013. The bill makes several significant changes to the Program.
• It increases the percentage of new jobs that a participant must hire from targeted groups to qualify for the Program from the current 35% to 50%. Under the bill, companies must hire 50% of their new jobs from at least one of the three targeted groups: enterprise zone residents, persons receiving some type of public assistance during the six-month period prior to employment, and persons who lack basic skills and are unemployable by traditional standards. Read More
After personally discovering what a challenge it was to navigate many State Board of Accountancy sites to verify a Certified Public Accountant (CPA) License, I decided to provide a better solution to access and verify a CPA License. What is listed below is the result of many hours of research locating the exact page (URL) on each of the State Board of Accountancy sites to verify any CPA License. The ability to access this information instantly gives consumers of tax services an answer to the most often asked question “How do you verify if a Certified Public Account has a CPA License?” Simply follow this link to verify anyone’s CPA License.
Social welfare, inappropriateness, resignations, hearings, and complexity—the Sec. 501(c)(4) story has it all…
This blog post is written in five parts:
1. The Sec. 501(c)(4) Story: Program Notes – Part 1 2. The Sec. 501(c)(4) Story: Program Notes – Part 2-Plot and Controversy #1 3. The Sec. 501(c)(4) Story: Program Notes – Part 3-Controversy #2 4. The Sec. 501(c)(4) Story: Program Notes – Part 4-Controversy #3 5. The Sec. 501(c)(4) Story: Program Notes – Part 5-Controversy #4 & ResolutionWhat qualifies for Sec. 501(c)(4) status, and how do other rules interact with this provision?
As described earlier, there can easily be challenges in determining if social welfare is an organization’s primary purpose. Other issues also exist. It is still unresolved whether contributions to Sec. 501(c)(4) organizations should subject the donor to gift tax, even though in 2011 the IRS announced it was closing current examinations and suspending further action on that question, noting it was a “difficult area with significant legal, administrative, and policy implications” (IRS memo and website (7/7/11)). Read More
Want To Gain Expert Knowledge And Skills Converting An Existing S Corp To An LLC? Complimentary Webinar
Secrets To Learn Working With A Retained Tax Recruiter Vs. Contingency
Legal Post: Texas Sales And Use Tax For Equipment Rentals
Canada Just Passed Law Increasing Exclusion Rate For Capital Gains To 66.6%
Biden Proposes Highest Capital Gains Tax in Over 100 YEARS
Recent Comments