Author Archives: Bradley Albin
Unrelated Business Taxable Income (UBTI) issues for Private Equity and Venture Capital Funds
Private Equity (PE) and Venture Capital (VC) funds often attract significant investment from US tax-exempt entities. In doing so, these funds may need to avoid having Unrelated Business Taxable Income (UBTI). This article will address some of the scenarios that can cause a fund to generate UBTI. US tax-exempt entities such as qualified pension funds, […]
Controlled Foreign Corporation (CFC) – Who is Subject to Taxation?
Can a US person who owns shares in a foreign corporation be subject to current taxation on the undistributed earnings and profits of that foreign corporation? The short answer to that question is that it is possible but as with everything US tax related, the answer depends on the facts and circumstances of each case. […]
IRS Update: Does your partnership agreement need to be revised?
Last month, the Internal Revenue Service (IRS) finalized proposed regulations on the designation and authority of a partnership representative under the centralized partnership audit procedures that went into effect for tax years after December 31, 2017. This article addresses some of the key points of the final regulations. Prior to discussing these regulations, we thought it […]
US Tax Reform: Final TCJA Highlights
On December 20, 2017, Congress passed H.R. 1 – the Tax Cuts and Jobs Act (TCJA) – providing for the largest changes to the US tax code since 1986 and President Trump signed the bill into law on December 22, 2017. As we have done previously, we have highlighted the changes made to US Federal […]
US Tax Reform: Senate Interpretation
This past weekend, the US Senate passed H.R. 1 – the Tax Cuts and Jobs Act – providing for the largest changes to the US tax code since 1986. The following is a list of “highlights” in the legislation (along with differences from the House bill passed on November 16, 2017): Corporate Tax Provisions Much like […]
Tax Reform: Trump v1 Highlights
On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released their initial attempt at tax reform. The document is entitled “Unified Framework for Fixing Our Broken Tax Code.” Some of the highlight items include: Consolidating the current seven income tax brackets into three brackets […]
You can run but can you still hide?
PLEASE NOTE: For new rules concerning single member foreign owned LLC’s please also read our post New IRS Reporting Requirements Foreign-owned US LLCs. With the passage and implementation of the Foreign Account and Tax Compliance Act (FATCA), much has been made of the US government’s attempt to crack down on its citizens’ use of accounts […]