It has become common for U.S. citizens to engage in business abroad through a foreign corporation.  Costa Rica is definitely one of the most favored countries in Central America, partially due to its reputation for stability.  It is important to understand, however, that U.S. citizens who engage in business abroad through a foreign corporation must [...]

The Foreign Account Tax Compliance Act (FATCA), was enacted in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act, and mandates new reporting requirements, and amends existing IRC Sections.  Recently, the IRS issued final regulations and guidance regarding the reporting interest paid to nonresident aliens by certain financial institutions, as well as [...]

A lot of taxpayers are still unaware that awards and prizes may be potentially subject to U.S. federal income taxation. In general, prizes and awards (other than certain types of fellowship grants and scholarships) should be included in gross income and subject to federal taxation. Awards for religious, charitable, scientific, educational, artistic, literary or civic [...]

Restricted Stock Units (RSUs) have become prominent in the news recently as a result of the Facebook IPO. Many of Facebook’s employees received RSUs in addition to their wages, and will soon be paying a heavy tax bill. Facebook has estimated that its employees’ total tax liability will be approximately $4 Billion dollars. In fact, [...]

This article will explain the basics of criminal tax investigations. It is extremely important if you find yourself under such an investigation, or believe that the potential for a criminal investigation exists in your case, that you obtain an experienced attorney to represent you. Internal Revenue Code (IRC) Section 7608(b) grants the right to the [...]

Virtually every business incurs some type of meal-related expenses. A question arises as to whether such meals are deductible and to what extent. This article provides a general overview of this topic; remember, though, that the deductibility of meals is highly fact-dependent and this article only provides an educational background to this issue, NOT a [...]

The Internal Revenue Code (IRC) permits individual and business taxpayers to deduct various types of taxes imposed by some tax authorities. However, some types of taxes are not deductible under the IRC. Here is a brief summary of most common non-deductible taxes: 1. Generally, federal income taxes, including social security and railroad retirement taxes paid [...]

The purpose of the article is to provide a brief historical overview of the circumstances leading up to the enactment of the famous “Subpart F” rules through the year 1962. Subpart F of Subtitle A, Chapter 1, Subchapter N, Part III of the Internal Revenue Code (IRC Sections 951-965) was first enacted by the U.S. [...]

In U.S. tax law, classification of income plays a very important role in determining your tax liability. One of the most important classifications is whether you have qualified dividend income eligible reduced tax rates applicable to certain capital gains – in most case, this means 15% tax rate. As with almost every issue in U.S. [...]

The Alternative Minimum Tax (the “AMT”) attempts to ensure that anyone who benefits from certain tax advantages pays at least a minimum amount of tax. Congress created the AMT in 1969, targeting higher-income taxpayers who could claim so many deductions they owed little or no income tax. The AMT provides an alternative set of rules [...]