A district court has determined on summary judgment that a 50% owner of a member-managed company, who was required to sign off on all significant decisions and actions relating to the company, was liable for the trust fund recovery penalty under Code Sec. 6672. The court found that his role in the company established that…
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Ireland Disagrees with EU's Decission That it Needs To Collect €13 Billion in Tax From Apple
On October 18, 2013 we posted Ireland to Close Highly Criticized Loophole, but Create an Even Bigger One where we discussed that Ireland said it planned to shut down a much-criticized tax arrangement used by Apple Inc to shelter over $40 billion from taxation, but will leave open an even bigger loophole that means the computer giant is…
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Issues Concerning Filing a Form 706NA?
On September 23, 2015, we posted "Some Nonresidents with U.S. Assets Must File Estate Tax Returns" where we discussed that deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets. Many foreigners owning property or assets in the United States are in violation of 706-NA…
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How Does CRS & FATCA Affect US Taxpayers?
On May 26, 2017 we posted Last Chance To Come Clean ... Automatic Exchange of Information Reporting Is Imminent! where we discussed that CRS participating jurisdictions began to exchange information in 2017 and returns where required to be submitted by May 31, 2017, including Crown Dependencies and Overseas Territories. We also provided a List of countries who have agreed to share…
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