Supreme Court Upholds Transition Tax in Moore v. U.S.
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On June 20, 2024, the Supreme Court issued its decision in Moore v. U.S., and put to bed a taxpayer challenge directed at the transition tax.
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Client Alerts
Appeal Dismissed: Aroeste v. U.S.
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On May 3, the Justice Department filed a motion in the Ninth Circuit to dismiss its appeal of the U.S. District Court for the Southern District of California’s decision in *Aroeste v. U.S.*
Read MoreTax Court Decision Reversed: Farhy v. Commr.
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Taxpayers who were cheered on by the Tax Court’s decision in Farhy v. Commr. (160 T.C. No. 6) will now be saddened by the reversal of that decision by the D.C. Circuit Court of Appeal.
Read MoreCorporate Transparency Act Held to be Unconstitutional
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In a case brought by The National Small Business Association and National Small Business United, the United States District Cour for the Northern District of Alabama held the C.T.A.
Corporate Transparency Act
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Beginning January 1, 2024, the Corporate Transparency Act (“CTA”) will impose certain reporting requirements on “reporting companies” to file with the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (“FinCEN”) reports containing personal information about the company’s beneficial owners and persons with control.
Read MoreWelcoming Michael Bennett to Ruchelman P.L.L.C.
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Michael Bennett advises clients on the U.S. tax aspects of cross-border matters, such as acquisitions, reorganizations, and business expansion.
Read MoreLooking Ahead: FinCEN to require virtual currency assets to be reported on the F.B.A.R.
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The Financial Crimes Enforcement Network (“FinCEN”) department of the Treasury has announced recently that it will begin requiring taxpayers to report virtual currency on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (known as the “F.B.A.R.”). Currently, FinCEN does not include accounts holding only virtual currency in the list of “reportable accounts” under the purview of F.B.A.R., but Treasury wants to change that.
Read MoreBureau of Economic Analysis BE-10 Report – Due Date by End of This Week
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It’s that time again… conducted every five years, the Commerce Department Bureau of Economic Analysis benchmark survey of U.S. Direct Investment Abroad, referred to as a BE-10 report, is due on May 29th.
Read MoreI.T.S.G. Global Tax Journal – New Edition
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I.T.S.G. publishes its Global Tax Journal five times each year. The current edition, released on May 6, 2020, addresses the responses to the COVID-19 pandemic by countries across the world.
Read MoreTreasury, I.R.S. Announce Cross-Border Tax Guidance Related to Travel Disruptions Arising from the COVID-19 Emergency
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The Treasury Department and the Internal Revenue Service today issued guidance that provides relief to individuals and businesses affected by travel disruptions arising from the COVID-19 emergency.
Read MoreCARES Act Loans and Business Tax Provisions
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As businesses have discovered, the CARES Act is an agglomeration of tax law and Small Business Administration rules. The concepts do not always mesh easily. Although working offsite, members of Ruchelman P.L.L.C. are available to assist in applying for relief programs.
Read MoreCorona Virus Phase 3 Relief
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This week, Senate Finance Committee Chairman Chuck Grassley (R-Iowa) released updated Phase 3 Corona Virus legislation responding to the public health and economic crisis.
Read MoreApril 15 Tax Payment Deferral Further Clarified
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In recent F.A.Q. guidance on the scope of delayed tax filing and payment, the I.R.S. announced that installment payments of transition tax are also delayed to July 15th.
Read MoreTax Day Moved to July 15
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The April 15 deadline for filing tax returns will now be postponed until July 15, according to Treasury Secretary Steven Mnuchin.
Read MoreApril 15 Tax Payments Deferred
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Following President Trump’s emergency declaration pursuant to the Stafford Act, the U.S. Treasury Department issued guidance on March 18, 2020, allowing all individual and other non-corporate tax filers to defer up to $1 million of Federal income tax (including self-employment tax) payments due on April 15, 2020, until July 15, 2020.
Read MoreFrench Social Security Charges (C.S.G. and C.R.D.S.) Are Creditable
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On June 26, the I.R.S. circulated an agency statement providing that the C.S.G. and the C.R.D.S. were not social “taxes” covered by the Totalization Agreement. The I.R.S. thus does not intend to challenge foreign tax credit claims for these two types of French social charges “on the basis that the Agreement on Social Security applies to those taxes.”
Read MoreFrench Social Security Charges (C.S.G. and C.R.D.S.) May Be Creditable
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Although the I.R.S. has recognized that foreign social security taxes imposed on net income may constitute creditable taxes for purposes of the Code §901 foreign tax credit provision, French social security charges have been denied such treatment in the past.
Read MoreI.R.S. Issues Proposed F.D.I.I. and G.I.L.T.I. Regulations
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On Monday, March 4, 2019, the I.R.S. released 177 pages of proposed regulations under the foreign-derived intangible income (“F.D.I.I.”) and global intangible low-taxed income (“G.I.L.T.I.”) regimes. They are scheduled to be published in the Federal Register today, March 6.
Read MoreI.R.S. Proposes Reduction in Overseas Income Inclusions For Corporate U.S. Shareholders
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The I.R.S. proposed regulations affecting a controlled foreign corporation (“C.F.C.”) and its U.S. Shareholders when the C.F.C. makes an investment in U.S. Property.
Read MoreI.R.S. Proposed Regulations Provide Clarity on Code §965 Transition Tax
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On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code §965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders holding interests in a deferred foreign income corporation (“D.F.I.C.”). A D.F.I.C. is any specified foreign corporation of a U.S. Shareholder that reports positive accumulated post-1986 deferred foreign income as of November 2, 2017, or December 31, 2017.
The proposed regulations modify and provide guidance in addition to three I.R.S. notices issued earlier this year. Here are some highlights.
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