The recent US Tax Court ruling in Wandry v Commissioner of Internal Revenue Service (IRS) has been welcomed by tax advisers to family businesses. The case was brought by a Colorado couple, Dean and Joanne Wandry. They owned a limited liability company called Norseman, worth about US$11 million in 2004. At that point they consulted…
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The US Experiences a Dramatic increase in Citizenship Renunciation during 2011.
According to Internal Revenue Service (IRS) figures, at least 1,800 Americans renounced their USA citizenship in 2011, an all-time record at eight times the 2008 number. The USA's worldwide taxation system, including the Foreign Bank and Financial Accounts (FBAR) and now the Foreign Accounts Tax Compliance Act (FATCA) regimes, is to blame, according to lobby…
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Less Than 9 Months Left To Make $10 Million Of Tax-Free Gifts
This may be the best time to transfer a large amount of wealth without transfer taxes. Unfortunately time is running out on this short term opportunity because the current generous gift-tax exemptions are scheduled to expire at the end of 2012. The lifetime exemption from Federal gift tax has been at its highest level the…
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Supreme Court Tells IRS 3 Years To Audit Is PLENTY! (Continued)
Home Concrete & Supply, LLC, (Sup Ct4/25/2012) 109 AFTR 2d 2012-661 The Supreme Court, resolving a split among various Circuit Courts and the Tax Court, has determined that an overstatement of basis isn't an omission of gross income for purposes of Code Sec. 6501(e)(1)(A)'s 6-year limitations period. The Court found that the '58 Colony decision,…
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