The IRS recently issued questions and answers (Q&As) regarding the transition tax imposed by Internal Revenue Code Section 965. Under finalized regs issued early in 2019, Sec. 965 generally requires U.S. shareholders to pay a “transition tax” on the untaxed foreign earnings of certain specified foreign corporations as if...
In January 2017, the IRS announced a new audit strategy for its Large Business and International (LB&I) Division known as “campaigns.” With the campaigns, LB&I essentially shifts its examinations based on compliance issues that the Division determines present greater levels of compliance risk. By targeting certain issues, the IRS...
If you have an interest in (or authority over) a foreign financial account, you may have to electronically file a form called the “Report of Foreign Bank and Financial Accounts” (FBAR). Failing to file a required FBAR can result in penalties. In the recent case of U.S. v. Park,...
Business owners often look for tax planning opportunities to reduce their overall tax burden. One highly discussed planning strategy is choice of entity – more specifically a Corporation that elects to be taxed under subchapter S of the Internal Reve Code, an S-Corporation. To understand the general landscape of...
Maintaining proper controls over your inventory can be challenging especially if you have no controls in place. Think about when was the last time you conducted an inventory check, if an employee was committing fraud, would you able to identify how? Having strong internal controls is essential to help...
Recently, rules changed regarding interest deductions for taxpayers. Since new regulations are coming into play under the Tax Cuts and Jobs Act, you may find yourself thinking twice about whether a business loan is the best option. When you pay on a business credit line, mortgage on your business...
In June, the IRS finalized certain proposed regs pertaining to the foreign tax credit (FTC). The final regs include changes to the rules that address the interaction between the FTC and Internal Revenue Code (IRC) Section 965(n) rules on not applying the net operating loss deduction when calculating the...
During the past couple of months, many businesses have been going through audits of their company’s retirement plan. As you may know, these compliance audits differ vastly from the traditional financial statement audits. This is due to not only the compliance regulations of these plans, but also the different...
Before you decide to invest in annuities, you need to know a few things about them so you can make sure it is the right kind of investment for you. While considering an annuity might seem like a wise choice on the surface, they are often misused and misunderstood....
The IRS has issued proposed regs that would ensure that the income of an S corporation will continue to be subject to U.S. income tax even when a nonresident alien (NRA) is a deemed owner of a grantor trust that elects to be an electing small business trust (ESBT)....