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
Read more →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
Read more →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 2.
Read more →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
Read more →Taxable income as calculated on the U.S. Federal Return for an S corporation flows through to its shareholders and is taxed at the individual level, not subject to self-employment tax. Because the income from the S Corporation is taxed when it is reported on the federal tax return
Read more →When a U.S. Partnership is formed and has one or several foreign individual partners who do not live in the United States, the income of such partnership to the partners must be assessed as to its nature to the partners in order to determine the amount of tax withholding to
Read more →In response to the ever-increasing number of taxpayers wanting online services, the IRS continues to develop online tools to interact with the taxpayers online, Commissioner John Koskinen said on April 2. Speaking at the National Press Club in Washington, D.C., Koskinen added that adequate funding is critical for
Read more →A divided House Ways and Means Committee approved six bipartisan tax bills on April 29. The tax incentive measures, popularly known as tax extenders because they often lapse and are restored by Congress, were taken from a comprehensive tax reform package introduced by Committee Chairman Dave Camp,
Read more →Did you know that nearly 80 million taxpayers use paid tax preparers, but 60% of those preparers are not regulated by the IRS? The reason for this is because the agency is only allowed to impose requirements on tax attorneys, enrolled agents, and Certified Public Accountants? The Government Accountability
Read more →There are dozens of temporary tax provisions that expired at the end of 2013. Most of these provisions have been part of past temporary tax extension legislation. Most recently, many temporary tax provisions were extended as part of the American Taxpayer Relief Act of 2012. Collectively, temporary tax provisions
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