On 7/26/2013 the Office of Chief Counsel issued Chief Counsel Advice (CCA) 201330033, where the IRS has addressed: ISSUES: 1. Does all or any portion of the Date 1 transfers of stock from the decedent to the grantor trusts in exchange for the notes with the self-cancelling feature constitute a gift? 2. How should the…
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Who Knew that Golf was such a Taxing Sport?
On Tuesday, March 19, 2013 we posted Professional Golfer Sergio Garcia "Whiffs" Tax Case regarding US Tax on "Image Rights" which discusses that the US Tax Court has ordered professional golfer Sergio Garcia to pay tax on endorsement income he had claimed was tax-free under the US-Switzerland tax treaty. The court decided Garcia's contract with…
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IRS Releases 2010 Form 8805 -Foreign Partner's Information Statistics.
Under the Tax Reform Act of 1986, U.S. partnerships are required to withhold income tax on "effectively connected taxable income" deemed allocable to foreign partners. The U.S. partnership must file a Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax, to show the amount of effectively connected taxable income and the total tax…
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Rodriguez, et al. v. Commissioner – Section 951 Inclusions Not Qualified Dividend Income.
Petitioner challenged the IRS's determination that the gross income petitioners reported in 2003 and 2004 based on their ownership of a controlled foreign corporation should have been taxed at the rate of petitioners' ordinary income rather than the lower tax rate they had claimed. At issue was whether amounts included in petitioners' gross income for…
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