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.
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 MoreMichael Bennett advises clients on the U.S. tax aspects of cross-border matters, such as acquisitions, reorganizations, and business expansion.
Read MoreThe 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 MoreIt’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. 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 MoreThe 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 MoreAs 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 MoreThis 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 MoreIn 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 MoreThe April 15 deadline for filing tax returns will now be postponed until July 15, according to Treasury Secretary Steven Mnuchin.
Read MoreFollowing 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 MoreOn 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 MoreAlthough 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 MoreOn 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 MoreThe 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 MoreOn 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.
Read MoreOn March 13, the I.R.S. announced it will end the Offshore Voluntary Disclosure Program ("O.V.D.P."). Taxpayers with undisclosed foreign financial assets have until September 28, 2018, to enter the 2014 O.V.D.P. and make complete disclosures.
Read MoreOn October 4, 2017, the Treasury revealed its plan to dismantle eight Obama-era tax regulations that it identified as having “increased tax burdens and impeded economic growth.”
Read MoreThe Trump administration's Tax Plan was announced this morning, September 26, 2017. The plan, called the "Unified Framework for Fixing Our Broken Tax Code," amounts to nine pages of policy measures that would reduce tax rates, limit many deductions, move the U.S. to a territorial tax system with a way to repatriate permanently invested earnings free of tax, treat business income of pass-through entities at lower corporate rates, and eliminate the estate tax.
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