Mar 26, 2018 | Firm Updates, International Tax
For the past few weeks we explored the regulations on Passive Foreign Investment Companies (PFICs), discussed how they are taxed, and examined how certain rules determine ownership and affect reporting requirements. In this post we will discuss the tax impact of...
Mar 23, 2018 | Firm Updates, International Tax
The IRS recently provided guidance for taxpayers affected by Section 965 of the Internal Revenue Code. In general, Section 965 requires U.S. shareholders to pay a transition tax on the untaxed foreign earnings of certain foreign corporations as if those earnings had...
Mar 22, 2018 | Firm Updates, International Tax
The Internal Revenue Service (IRS) recently announced that the 2014 Offshore Voluntary Disclosure Program (OVDP) will end on September 28, 2018. The advance notice is intended to give U.S. taxpayers with undisclosed foreign financial assets enough time to use the OVDP...
Mar 20, 2018 | Firm Updates, Individual Tax, Tax Tips
Home ownership is a key element of the American dream for many, and the U.S. tax code includes many tax breaks that help support this dream. If you own a home, you may be eligible for several valuable breaks when you file your 2017 return. But under the Tax Cuts and...
Mar 19, 2018 | Firm Updates, International Tax
In the previous posts we introduced the passive foreign investment company (PFIC) rules and discussed how they are treated for taxation purposes. We touched on how to determine if a fund is a PFIC and the most common type of PFIC. In this post we’ll describe the...