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2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers
As the new year 2020 begins, it is important for US taxpayers with undisclosed foreign assets to consider their 2020 offshore voluntary disclosure options. Unlike last year, there have not been any drastic changes to the voluntary disclosure options since 2019. In this article, I would like to generally explore the 2020 offshore voluntary disclosure […]
26 U.S.C. Subpart A: Taxation of Recipients of Corporation Distributions
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerThis article is a second installment of our series of articles on corporate distributions. Today’s topic is the description of 26 U.S.C. Subpart A, which contains the most important tax provisions for our subsequent discussions of this subject. 26 U.S.C. Subpart A: Purpose 26 U.S.C Subpart A is the first part of Part I of […]
Introduction to Corporate Distributions | US Business Tax Law Firm
/in business tax lawyers minneapolis, Legal Notes /by ManagerThis essay opens our new series of articles which focuses on corporate distributions. The new series will cover the classification, statutory structure and tax treatment of various types of corporation distributions, including redemptions of corporate stock. This first article seeks to introduce the readers to the overall US statutory tax structure concerning corporate distributions. Corporation […]
The Tinkov Case: Concealment of Foreign Assets During Expatriation
/in international tax lawyer, Legal Notes /by ManagerOn March 5, 2020, the Internal Revenue Service (“IRS”) and the U.S. Department of Justice (“DOJ”) announced that Mr. Oleg Tinkov was arrested in London in connection with an indictment concerning concealment of about $1 billion in foreign assets and the expatriation income in connection with these assets. Let’s discuss the Tinkov case in more […]
§318 Entity-Member Attribution Summary | International Tax Lawyer
/in international tax lawyer, Legal Notes /by ManagerIn a previous article, I discussed the IRC (Internal Revenue Code) §318 sidewise attribution limitation. This limitation was the last piece in the jigsaw puzzle of the §318 entity-member attribution rules; now, we are ready to summarize these rules in light of this exception. This is the purpose of this article – state the §318 […]
July 15 Deferral: More Deadlines Affected | US International Tax News
/in International Tax Attorney, Legal Notes /by ManagerOn April 9, 2020, the IRS announced additional relief to taxpayers by moving the due date for more deadlines to July 15, 2020. Let’s discuss this additional July 15 Deferral in more detail. July 15 Deferral: Background Information On March 13, 2020, in response to the 2019 coronavirus (also called “COVID-19″) pandemic, President Trump issued […]