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IRS Eases FATCA Compliance Rules
Jan 25, 2019
On December 18, 2018, the IRS released proposed regulations that are intended to clarify, reduce and/or eliminate certain FATCA reporting requirements. The proposed regulations address a number of items, with the more salient items described here.
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Proposed Regulations on Section 965 Released
Sep 13, 2018
The IRS released proposed regulation Section 965 which generally requires a “U.S. shareholder” to pay a “transition tax” on the earnings of a deferred foreign income corporation as if such earnings had been repatriated to the U.S.
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Final Regulations Issued Regarding Foreign-Owned U.S. LLCs and Reporting Requirements
Dec 20, 2016
Under the “check-the-box” regulations, a business entity with a single owner can be disregarded as separate from its owner for various tax purposes and may not be required to file a U.S. income tax return or obtain an employer identification number (“EIN”).
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The Puerto Rican Default Doesn’t Impact You? Think Again.
Jul 19, 2016
Millions of Americans are invested in muni-bond funds from Oppenheimer, Goldman Sachs and others. These funds are some of the largest holders of Puerto Rico’s debt. Steps you can take to mitigate certain bond-market risks.
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U.S. Banks Must Report Interest on Deposits by Nonresident Aliens
Apr 30, 2012
U.S. Banks and interest on deposits by nonresident aliens. IRS released regulations requiring reporting of interest on deposits maintained by nonresident alien individuals. Reporting institutions can rely on the permanent address provided on a valid IRS Form W-8BEN. The IRS is in process of finalizing regulations under the U.S. Foreign Account Tax Compliance Act FATCA.
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Sep 10, 2015
In what no doubt will be considered a precedent setting case, the Tax Court recently invalidated Treasury Regulations which require related parties who enter qualified cost-sharing arrangements (QSCAs) to share stock-based compensation (SBC).
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Increased Enforcement by the U.K.’s Serious Fraud Office
Apr 4, 2014
To fight crime and corruption, the U.K. Ministry of Justice is aggressively enforcing the U.K. Bribery Act. It has the potential to cover many global organizations including U.S. business organizations doing business with U.K. organizations or affiliates.
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Important Changes to Offshore Voluntary Disclosure Program
Jul 9, 2014
Information on compliance with U.S. tax filings. Important changes Offshore Voluntary Disclosure Program and expansion of offshore-related Streamlined Filing Compliance Procedures. Taxpayers whose actions were not willful have greater flexibility in avoiding penalties.
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Foreign Currency Matters Under ASC 830
Jan 4, 2017
The entire task of foreign currency translation can be understood as determining the correct exchange rate to be used in converting each financial statement line item from the foreign currency to USD. ASC 830 establishes these steps.
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EisnerAmper International Tax Alert
Aug 16, 2010
International Tax Alert about The Education Jobs and Medicaid Assistance Act of 2010 which creates significant changes to International Tax. This International Tax Alert contains details on the most significant changes. Companies should diligently review and evaluate their multi-national organizational structures to determine the impact of these changes to their foreign tax credit planning, Subpart F planning, and acquisition planning.
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Alternative Investment Fund International Tax Developments
Mar 5, 2012
Alert for alternative fund industry and international tax developments. U.S. legislation in FATCA provisions will tax investors on capital gains from the sale of U.S. securities. Indian DTC imposes General Anti Avoidance Rules GAAR provisions. Vodafone case impact on non-resident investments in India. Tax Treaty Update - the Double Taxation Avoidance Agreement (DTAA) with India.
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Seven Tips For Law Firms in Year-End 2021 Tax Planning
Dec 16, 2021
This article features observations on tax tips law firms can utilize for year-end tax planning.
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Should NJ Professional Services Firms Take the “BAIT?”
Feb 1, 2021
New Jersey’s Pass-Through Business Alternative Income Tax (“BAIT”). Has become a more attractive option, particularly for professional service firms, since the recent IRS Notice on state-sponsored pass-through entity and SALT workarounds.
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Eight Tips for Law Firms When Filing 1099s
Dec 16, 2020
Here are eight tips for law firms as they work with the new Form 1099-NEC and the revised Form 1099-MISC—along with the typical pitfalls of 1099 reporting.
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Transforming the Law Firm Workforce with Robotics Process Automation
Feb 21, 2020
a discussion of the advantages available through the use of robotics process automation.
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NJ Adopts Market Sourcing for Corporate Service Providers
Oct 28, 2019
An overview of the change of how New Jersey records corporate revenue sourcing to the market-based method. It further states that the impact will be on S and C corporations.
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Connecticut’s 2019 Legislative Changes Affect Pass-Through Entity Tax
Sep 20, 2019
The impact of recent law changes in Connecticut regarding the taxation of pass through entities, such as law firms.
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California’s “TCJA Lite” Avoids Decrease in Taxpayer’s Portion of M&E Deductions
Aug 13, 2019
California codifies legislation designed to apply the meals and entertainment deduction portion of 2017 tax reform. Included is a breakdown of the expense, the federal deduction and the corresponding California deduction.
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Four Tax Considerations in Settling a Legal Dispute: Begin with the End in Mind
Jul 18, 2019
When setting legal disputes, proper planning is key. And, even if you anticipate that your client will be taxed on the entire recovery, recognizing that fact early is crucial so you can negotiate with the net recovery in mind.
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Why SOC Reports Can Help You Sleep at Night
Jun 27, 2019
You can obtain that vendors have robust internal controls by a Service Organization Controls (SOC) report that details system design, control objectives, security, related testing, results and so forth.