Archive for the Tax Planning Category

S. 2260 – Expiring Provisions, Improvement, Reform, and Efficiency (EXPIRE) Act of 2014

go to link Below is the Senate version of the tax extenders bill, the EXPIRE Bill of 2014.  All items listed below have expired or will expire in 2014 that this bill has called to extend two to three more years. TITLE I—PROVISIONS EXPIRING IN 2013 Subtitle A—Individual Tax Extenders…

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Extenders Negotiations Continue with a cold White House Response

http://acf.ch/wp/?m=home-construction-loan-banks Negotiations over the fate of more than 50 tax extenders have continued over the Thanksgiving recess. Leaders in both the House and Senate have been in discussions over whether to extend the popular but temporary tax breaks or to make permanent some of the incentives and eliminate…

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Action Needed to Ensure Tax Compliace with FIRPTA

http://cfpaldomoro.it/?m=how-is-interest-calculated-on-a-mortgage-loan According to new audit report from the Treasury Inspector General for Tax Administration (TIGTA), current IRS procedures are insufficient to ensure that all foreign seller real estate transactions subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) are in fact compliant with FIRPTA.…

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US Treasury Official Discusses BEPS and Other International Tax Developments

follow url Robert Stack, Treasury deputy assistant secretary (International Tax Affairs), predicts that the department will face a difficult year in 2015 as it begins to tackle several of the tougher issues listed in the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action…

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Anti-Inversion Proposals Put 42,000 U.S. Jobs at Risk of Going Overseas

where can i get a payday loan with a starter check Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found…

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Court Denies Basis To Partners For Contributions of Notes, But Waives Penalties

little loan shoppe investors The Tax Court has denied basis to individuals who contributed unfunded, unsecured notes to a partnership and claimed basis for the amounts on the notes. As a result, the partners’ bases in their partnership interests were too low for them to claim greater pass-through losses on their…

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Chief Counsel on What Makes Amounts Paid To “Limited Partners” of an LLC Subject To Self-Employment Taxes

source link IRS Chief Counsel (CCA 201436049) has concluded that so-called limited partners of an investment management firm were not limited partners of the firm (a limited liability company (LLC) treated as a partnership) and were being paid compensation for services. Therefore, the amounts they received from the firm…

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IRS and Treasury Take Action Against Corporate Inversions

http://hiddenacres.ca/site/?m=legal-loan-forms-free The Treasury and the IRS have announced that they will be taking targeted action against corporations employing a technique known as a tax inversion in order to avoid taxation, and have issued a fact sheet and a Notice in that respect. What happens with an inversion, is…

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IRS’ Overhaul of Streamline & Offshore Voluntary Disclosure Program “OVDP”

On June 18, 2014, the IRS announced comprehensive changes to both the Streamlined and the Offshore Voluntary Disclosure Program (“OVDP”) programs. Such changes to the Streamline Program include: Streamlined Program 1. Expanded to include both U.S. citizens living abroad and U.S. citizens living in the United States…

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Final Regs Issued for Small Business Healthcare Tax Credit

Section 45R(a) provides for a health insurance tax credit for eligible small employers for any taxable year in which they have a qualified contribution arrangement, have no more than 25 full-time equivalent employees (FTEs), and the average annual wages of its FTEs does not exceed $25,000 (as…

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