Foreign residents beware, laws have been passed to restrict your access to claim the CGT main residence exemption on the sale of your home, except in some limited circumstances. This applies to any person that is not an Australian resident for tax purposes at the time of disposal (ie when the contract is signed to sell the property).Read more
PROPOSED REGULATIONS REDUCING THE AMOUNT DETERMINED UNDER SECTION 956 WITH RESPECT TO CERTAIN DOMESTIC CORPORATIONS ISSUED
On October 31, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations under Section 956, Investment of earnings in United States property, (the Proposed Regulations). The Proposed Regulations reduce the amount determined under Section 956 with respect to certain domestic corporations that own (or are treated as owning) stock in foreign corporations. Read more
There have been many changes in the last 12 months for US taxation of foreign entities. US shareholders of controlled foreign corporations (CFCs) have already felt the pinch of transition tax for 2017. Unfortunately, the pinch of foreign taxation changes is going to continue in 2018 and onwards thanks in part to GILTI. As the acronyms connotation implies, it is a less than popular tax change. Let us look together at some significant points related to the ominous GILTI: Read more
By Bethany Bouw, CPA
Tis the season when those far and wide give gifts to their loved ones and charities. While you may be giving purely for the benefit of others, this does not remove the need to be aware of IRS requirements and regulations. Though the recipients will appreciate your altruistic intent, the IRS still has expectations no matter the spirit of the season. So, lest you fall afoul of the reporting rules, here are three commonly asked questions to consider as you gift and donate internationally this holiday season. Read more
By Bethany Bouw, CPA
We see much in the news about people expatriating – jokes related to a political climate (regardless of administration), trying to avoid tax (think that Facebook co-founder who renounced citizenship), and those who have spent the majority of their lives abroad, etc. Unfortunately, relinquishing citizenship and ending long-term residency is not as easy as mailing in your passport or green card and booking a flight with your belongings. There is much more involved from a tax perspective when expatriating and it should be done with input from an attorney and a qualified tax professional. Below you will find 10 starting questions and answers regarding expatriation and Form 8854, Initial and Annual Expatriation Statement. Read more
More now than ever people travel, work, and live all around the world. Therefore, understanding how to deal with foreign currency is becoming even more relevant. Taxpayers who have transactions in foreign currencies often wonder what they need to report and how they get the foreign currency into US dollars. Let’s review four of the most widely asked question regarding a taxpayer’s responsibility when dealing with foreign currency. Read more
On October 1, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued Notice 2018-78 (the Notice). The Notice provides guidance with respect to the basis election under Prop. Reg. §1.965-2(f)(2), the application of rules for disregarding certain assets for determining aggregate foreign cash position in Prop. Reg. §1.965-3(b) to consolidated groups and relief in connection with Hurricane Florence. Read more
TREASURY ISSUES PROPOSED REGULATIONS FOR GLOBAL INTANGIBLE LOW-TAXED INCOME, SECTION 951A
On September 13, Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations (REG-104390-18, hereinafter, the Proposed Regulations) implementing Section 951A. Read more
By Bethany Bouw, CPA
Taxpayers who have foreign businesses are often surprised to hear there are filing requirements to disclose their business. If you are familiar with the basics of international business, you may know this is true of foreign corporations. The same is true of partnerships, sole proprietors, other foreign disregarded entities and more. In many cases, taxpayers assume that if they keep most aspects of their business abroad, that the IRS will have no interest in them. Unfortunately, they are incorrect.
What is GILTI?
The Global Intangible Low-taxed Income (GILTI) is a new provision, enacted as a part of tax reform legislation. Mechanically, it functions as a global minimum tax and introduces a lot of issues for all U.S. shareholders of controlled foreign corporations (CFCs) – especially individuals and partnerships. Read more