According to Law360, although taxpayers have already calculated and reported their Section 965 deemed repatriation tax, Section 965 will have a continuing impact. Taxpayers are well advised to review their approach to estimated taxes. The IRS refuses to issue refunds of overpaid income taxes to taxpayers who elected to pay Section 965 taxes in…
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EB-5 Investment – New Regulations Expected To Increase Minimum Investment of $500,000 To $1.35 Million
On June 27, 2019 the Office of Management & Budget (OMB) reported on its website that it has finished its review of the Obama-era regulations that would significant changes to the minimum investment amount, as well as other consequential changes. The regulations have proposed increasing the minimum investment of $500,000 to $1.35 million, and the…
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How NOT To Handle an IRS Collection Matter
According to DoJ, Wagdy A. Guirguis, owner of several engineering businesses, was sentenced June 28, 2019 to 5 (five) years in prison in Honolulu. On Nov. 20, 2018, a jury convicted Guirguis of: Conspiracy to defraud the United States along with co-conspirator Michael Higa, Three counts of filing false corporate income tax returns, One…
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U.S. Citizen Resident in US Possession Was A Nonresident/Noncitizen For Estate, Gift, GST Purposes
A taxpayer who was born outside the U.S. and its possessions, whose parents were not U.S. citizens at the time of his birth, and who became a U.S. citizen after residing in a U.S. possession was a "nonresident not a citizen of the U.S." for estate, gift, and generation skipping transfer tax (GST) purposes. PLR…
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