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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 […]
The Internal Revenue Service, Deputy Commissioner (International), Large Business and International Division (“LB&I”), announced certain organizational and administrative changes and transitional procedures in connection with the creation of the Advance Pricing and Mutual Agreement (“APMA”) program. Prior to February 26, 2012, the Advance Pricing Agreement (“APA”) program was part of the Office of the Associate […]
The U.S. Department of Treasure recently published its official currency conversion rates for December 31, 2011 (they are called “Treasury’s Financial Management Service rates”). These rates are important for many reasons, but one reason especially stands out for persons who are required to file the FBARs. The latest (January 2012) FBAR instructions require the use […]