Relief procedures for former U.S. citizens

Posted by on Sep 11, 2019 in 2019 Articles | 0 comments

The IRS recently released certain relief procedures for U.S. citizens who relinquished U.S. citizenship (‘an expatriation event”) after March 18, 2010 who are delinquent in their U.S. tax filings.

The purpose of  this relief is to allow eligible  individuals to escape the potential income tax implications of IRS Code 877A upon expatriation as well as interest/penalties and tax  payable for unfiled tax and information returns.  

Readers may refer to my 2017…

read more

Cross Border Intercorporate Transactions

Posted by on Sep 2, 2019 in 2019 Articles | 0 comments

Several enquiries have been received by companies wishing to do business in the United States, some have already incorporated, and some are just in the investigative stage(s).

Annual professional fees can very much be a function of your annual or ongoing compliance costs such as corporate federal and state filings. The latter can increase fees significantly if one is doing business in various states, and whether income tax, franchise tax or…

read more

IRS Form 8233

Posted by on Aug 8, 2019 in 2019 Articles | 0 comments

This form is used for a non-U.S. person to have the U.S. payor (considered a withholding agent) to reduce the amount of U.S. tax to be withheld on personal services provided in the United States. The individual providing the service could be an employee or an independent contractor, sole proprietor.

It is possible for a Canadian corporation to …

read more

Revised GILTI provisions offer reprieve to U.S. individual investors

Posted by on Mar 19, 2019 in 2019 Articles | 0 comments

Commencing in 2017, the December 2017 Tax Cuts and Jobs Act required  U.S. persons to be taxed on accumulated profits, generally derived from active business income of controlled-foreign corporations (“CFC”s) under section 965 of the IRS Code. This was also known as the transition or repatriation tax. Currently and prior to 2017, specific types of income earned by the CFC, primarily…

read more

Revised U.S. Estate/Gift Tax Exclusions

Posted by on Jan 11, 2019 in 2019 Articles | 0 comments

The December 2017 Tax Cuts and Jobs Act doubled the lifetime exclusion to $11.18M effective for 2018 to 2025, subject to inflation adjustments for subsequent years. The unified tax credit relating to the 2018 exclusion is $4,417,800. For 2019, the exclusion amount is expected to be $11.4M with a unified credit of $4,505,800.

After 2025, the foregoing may or may not be approved by Congress to be of…

read more