Recently, you may have read news headlines about certain “bad” people who hide money in offshore accounts and don’t report the income to the IRS. Some of these headlines involve serious cases of tax evasion with criminal elements. However, many of the recent cases involve something more benign, but nonetheless worthy of huge monetary penalties,…
Don’t Be Fooled By Phony IRS Websites As we continue in our series of tax tips to assist in making taxpayers more aware of the proactive initiatives that the Internal Revenue Service (“IRS”) has undertaken, this tax tip focuses on the issue of phony IRS website scams. As identity theft continues to be a prevalent…
SEC EXAMINATIONS TO LOOK OUT FOR I thought I would get back into the saddle and write this week’s blog. Seems Tony and Bob are knee deep in reviewing tax returns, literally. I walked by and for an office that is supposed to be paperless there were returns piled on their desks so high that…
Recording Services From An Affiliated Entity Not-for-Profit (“NFP”) organizations, at times, receive services from personnel of an affiliated entity. However, the question is then raised, “Should we record the value of services received if we are not billed for those services, and if so, how should that value be determined?” Steps on recording services from…
Fund Manager Seeks Sun, Fun and Low Taxes: Expatriation with a New Twist Have you ever been so disgruntled about paying taxes that you start daydreaming about renouncing your U.S. citizenship and moving to a low tax jurisdiction? Normally, the concept is not as rewarding as it seems. Expatriating from the U.S. actually causes a…
Inside the Life of a Dutch Entrepreneur GUEST BLOGGER Corney Versteden, LLM Senior Tax Partner HLB Van Daal & Partners NV in Waalwijk, The Netherlands While I was flying to Hong Kong last week, I realized that Dutch entrepreneurs no longer sail the oceans in big ships. They now fly around the world in…
Transfer Pricing – Loans (from “A Primer on Transfer Pricing” by Robert J. Misey, Jr., updated by Kimberlee S. Phelan) Reminder of the example: NJComanufactures and sells widgets in the U.S. due to increased widget orders from Canadian customers and also decides to form a Canadian distribution subsidiary (“CanSub”). Although CanSubdoes not have any manufacturing…
Withholding of Tax on Dispositions of US Real Property Interests Do any of your clients have foreign owners that have an interest in US real property? If a foreign owner sells the interest in the US entity, another level of withholding would apply to the transaction. Dispositions of US real property by a foreign person…
The Most Complicated Partnership Tax Return, Ever I told Frank that I, Bob Demmett, would write the blog this week to publicly thank him for giving me one of the most complicated partnership tax returns, ever. As Frank mentioned in last week’s blog, this client had everything: contribution of appreciated property, foreign partners, Section 754…
There have been several events in the last few years, which should cause fiduciaries of employee benefit plans to take particular notice. If these events were not compelling enough, there have also been several high profile court cases against plan fiduciaries (most notably Tussey vs. ABB). The decisions in these court cases have set the…