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...
Aug 20, 2018 | Firm Updates, International Tax
On our International Tax Blog, we have been discussing two fictional taxpayers, John and Sue Ling, who have resided in the United States for many years. They have been working with their CPA and attorney on their estate plans. John is a U.S. citizen but Sue is not,...