If the IRS is after you to collect a tax liability that is beyond your capacity to pay, you should be aware of a technique that may allow you to settle your tax debt for less than the full amount you owe. It's called an Offer in Compromise.
Like any creditor, IRS prefers a partial payment to no payment at all. Thus, IRS is sometimes willing to settle a tax ... Read More
By: Chris Catarino, CPA, MT and Joseph Criscuolo, CPA
Buried in the 2018 instructions to Form 1065, U.S. Return of Partnership Income, is a new reporting requirement with a whopping noncompliance penalty. The blow-back from practitioners on this sneaky new disclosure was so great the IRS issued penalty relief provisions this week… here's the ... Read More
As trusted advisors, we are asked by entrepreneurs to consult with them on the myriad of tax issues related to the startup phase of a new business enterprise. Before we discuss any tax issues, it is imperative that resources and time are dedicated to understanding how the business will operate. Questions to be asked are: “what kind of goods or services will be provided?”, “what is the anticipated market ... Read More
The Tax Cuts and Jobs Act of 2017 (“TCJA”) made one of the most important decisions when starting a new business--choosing an entity type, even more important. The tax considerations associated with the type of entity chosen now has greater consequences under the TCJA and should be explored in greater detail. Here, we will look at the differences in the two main categories of entity structures.
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Under the newly enacted Section 951A, beginning in tax year 2018, each U.S. shareholder of a controlled foreign corporation (CFC) is subject to current U.S. income tax on their share of global intangible low-taxed income (GILTI). GILTI is defined as the excess (if any) of a U.S. shareholder’s net CFC-tested income over their net deemed tangible income return (NDTIR). In September 2018, ... Read More
Since 2016, the penalty for estimated tax underpayments has steadily increased. The rate has doubled since 2015 after years of not changing at all. Taxpayers should pay close attention to this trend. It should no longer be taken lightly or ignored, and here’s why.
Today, we focus on the rising penalty associated with underpaying ... Read More
By: Patrick J. McCormick, J.D., LL.M. and Michael Rock, CPA
Welcome to Part II of our Non-Resident Alien Withholding blog. Today, we’ll look at the consequences of failing to withhold (or incorrectly withholding) on nonresident alien taxes.
As detailed in Read More
By: Patrick McCormick, J.D., LL.M. and Michael Rock, CPA
Complying with domestic U.S. tax law can be tough; when foreign taxpayers are brought into the mix, the complexity can become overwhelming. In today’s global society, U.S. taxpayers (both businesses and individuals) are engaging in transactions with nonresident aliens more than ever. In part one of ... Read More
Buried within the Tax Cuts and Jobs Act of 2017 are six pages that create a massive tax-savings opportunity. Sections 1400Z-1 and 1400Z-2 define a completely new tax incentive for Qualified Opportunity Zones and Qualified Opportunity Funds. In short, individuals with capital gains obtain tax benefits by investing those gains in Qualified Opportunity Funds, which, in turn, invest in economically distressed areas designated as Opportunity Zones.
It’s a hot topic, and although recent ... Read More
Last year, we discussed Internal Revenue Code §163(j) created by the Tax Cuts and Jobs Act of 2017 ("TCJA"). At the time, we knew business interest expenses were limited to 30% of Adjusted Taxable Income + business interest income + floor plan financing interest expense. We also knew businesses with gross receipts of $25 million or less were "excepted" from the limitation and that ... Read More
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