Share Statute of Limitations for Foreign Reporting Forms Missing foreign filings may subject to entire tax return to extend statue of limitations. These exceptions essentially give the IRS the ability to audit a tax return outside of the normal statute of limitations if the return is missing any of the specified foreign reporting forms. Extended…
IRS Reminds Delinquent Small Retirement Plans of Looming June 2 Deadline for Penalty Relief Certain small businesses that have failed to timely file required retirement plan returns have until June 2, 2015, to take advantage of a special penalty relief program that was launched last year. The IRS established a temporary one-year pilot program to…
The following ten items should be considered during the not-for-profit budgeting or budget revision process depending on the type of budget being prepared: Use actual results from the prior year and the current year actual costs projected to year end as well as the prior and current year budget as starting point. Analyze budget variances…
Dividend Equivalent Withholding Regulations Delayed until January 1, 2017 On May 8, 2015, I had the pleasure of speaking on a panel with Karl Walli, Senior Counsel (Financial Products), Office of Tax Legislative Counsel, U.S. Department of the Treasury, where I was able to quiz Karl about the proposed regulations under Section 871(m). Karl announced…
Foreign-Trade Zones – What Should You Know? Foreign-Trade Zones (FTZs) are designed to generate economic growth and development in the United States by encouraging firms to site and expand their U.S. operations within the zones. Rules related to FTZs are designed to put U.S. manufacturers on equal footing with foreign competitors through special rules related…
Foreign Investors Challenge India’s Minimum Alternative Tax Aberdeen Asset Management, Europe’s largest listed fund house, filed its petition May 2, 2015, at the High Court of Bombay, confirming that it planned a legal fight against India’s Minimum Alternative Tax (“MAT”). Historically foreign funds, like Aberdeen, have been exempt from this form of taxation. Recently, tax…
Teamwork – No Successful Entrepreneur Should Leave Home Without It “We got the tools; we got the talent.” – Winston Zeddemore from Ghostbusters I am often asked what makes one company more successful than another. Many think it is the uniqueness of the product or the ability to obtain financing that results in success. I…
Option pricing models attempt to set a current theoretical value. Models use certain fixed contractual terms – factors such as underlying price, strike and days until expiration – along with forecasts (or assumptions) for factors like implied volatility, to compute the theoretical value for a specific option or a warrant at a certain point in…
IRS Proposes New PFIC Insurance Exception Readers, we are continuing to follow along with the saga between Senator Ron Wyden (former Chair of the Senate Finance Committee) and IRS Commissioner, John Koskinen, regarding hedge fund sponsored reinsurance companies which I’ve written about before here. Inside of the promised 90-day deadline, on April 23, 2015, the…