Oct 22, 2018 | Firm Updates, International Tax
The IRS issues Individual Taxpayer Identification Numbers (ITINs) to individuals who are required to have a U.S. taxpayer identification number but who do not have (and are not eligible to obtain) a Social Security number. Certain ITINs expire at the end of each year,...
Oct 1, 2018 | Firm Updates, International Tax
In a previous blog post, we discussed some of the tax options available when a U.S. taxpayer goes overseas for employment. A popular option is to use the Foreign Earned Income Exclusion (FEIE). The FEIE is especially useful now that the Tax Cuts and Jobs Act (TCJA)...
Sep 26, 2018 | Firm Updates, International Tax
As we previously reported, the Internal Revenue Service (IRS) will close the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. The OVDP was launched in 2009 to encourage compliance with foreign asset reporting, allowing U.S. taxpayers a way to avoid...
Sep 18, 2018 | Firm Updates, International Tax
The Internal Revenue Service (IRS) recently proposed regulations concerning the treatment of global intangible low-taxed income (GILTI). The regulations are a result of the Tax Cuts and Jobs Act (TCJA), which added new rules requiring the inclusion of GILTI generated...
Sep 6, 2018 | Firm Updates, International Tax
The New York State Department of Taxation and Finance recently released notices on the tax treatment of IRC § 965 repatriation amounts for tax year 2017 for corporations and flow-through entities. The Tax Cuts and Jobs Act requires certain U.S. taxpayers to recognize...
Aug 27, 2018 | Firm Updates, International Tax
We have been discussing two fictional taxpayers, John and Sue Ling, who have been residing in the United States for many years. John is a U.S. citizen but Sue is not, although she is a permanent U.S. resident. John is 12 years older than Sue and should he predecease...