Articles & Resources
Was Your SSN Stolen in a Recent Massive Data Leak?
A group that calls themselves USDoD hacked into the database of National Public Data, which is a background check company, and claimed to steal 2.7-2.9 billion people’s personal information.
Potential NIIT Relief for International Taxpayers
A recent ruling in 2023 by the U.S. Court of Federal Claims allowed U.S. citizens living in France to offset the net investment income tax using the foreign tax credit for taxes that are paid in France. This outcome is different from a previous court case on this same issue. The IRS has appealed the ruling leaving taxpayers in limbo waiting on the final decision regarding the relationship between the net investment income tax and foreign tax credit.
US-Chile Tax Treaty Ratified, Further Strengthening Economic Ties
On December 19, 2023, the U.S. Treasury Department announced that the U.S.-Chile Income Tax Treaty is now in force. The treaty provides for reduced withholding tax rates on interest, dividends, and royalties, as well as seeking to eliminate double taxation.
Lifting the Veil: An In-depth Examination of Enhanced Disclosure on Private Companies Under the Corporate Transparency Act
In anticipation of the broad, encompassing Corporate Transparency Act coming into effect in fiscal year 2024, virtually all new and existing entities conducting business in the United States must provide essential business and personnel information or face steep civil and criminal penalties.
Tax incentives for selling to foreign customers: Foreign-Derived Intangible Income Deduction
The 2017 Tax Cuts and Jobs Act (TCJA) brought significant changes to the U.S. tax code, including the introduction of a new deduction called the Foreign-Derived Intangible Income (FDII) deduction. The aim of this deduction is to incentivize U.S. C corporations to promote exports and service foreign markets.
Proposed Regs Issued on the New Clean Vehicle Credit
The Internal Revenue Service issued proposed regulations on April 17, 2023 for IRC Section 30D that detail the mandatory mineral and battery component requirements of the new clean vehicle credit and provide guidance on a few other critical areas for the credit. For the most part, the proposed regulations agree with previous IRS guidance. The majority of the regulations are proposed to affect new clean vehicles placed in service after April 17, 2023.
Clock is Ticking on “Get out of Jail Free Card”
For taxpayers living and working abroad, it can be quite complicated trying to determine how to file taxes in not one but two tax jurisdictions. The penalties for failing to comply in the U.S. are astronomical. But the clock is ticking on ticking on getting into compliance. Not only does the IRS have additional funding and has recently hired 4,000 more agents but we have a new IRS commissioner. What does that mean for the existing amnesty programs for taxpayers who have either failed to report some of their foreign income or foreign assets? The clock is ticking…
Georgia lets parents claim a $3,000 tax deduction for embryos
The repeal of Roe vs. Wade is having all sorts of unintended consequences, even in the tax world. In an effort to conform Georgia’s abortion law to tax law, Georgia has changed the definition of a tax dependent to include any humans, including an unborn child. This will result in an additional Georgia tax deduction of $3,000 for each unborn child.
Corporate tax hike on large multinational companies
On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (“IRA”), designed to reduce inflation and provide investments in clean energy. The bill has several key provisions, one of which is a new 15% corporate minimum tax on large corporations.