According to Law360, The IRS has announced six new compliance campaigns focused on issues affecting U.S. nationals' overseas income, capital gains taxes for some pass-through businesses and certain forms of deferred compensation for services. A statement from the Internal Revenue Service's Large Business and International division didn't include a launch date for the campaigns, but their…
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Senate OKs Tax Treaties With Spain, Japan, Switzerland & Luxembourg
According to Law360, The U.S. Senate on July 17, 2019 approved three bilateral tax treaties with Switzerland, Luxembourg and Japan, one day after approving a treaty with Spain. The Senate overwhelmingly approved the treaty protocols, which are, in part, designed to help prevent companies from being subject to double taxation. The Swiss treaty passed by a 95-2…
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Gov't Received 39% of Projected 965 Income – Expect Increased IRS Audit of Forms 5471
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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