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2022 UK Autumn Statement: Are you affected?

The UK Chancellor, Jeremy Hunt, this morning delivered his much-anticipated Autumn Statement. He promised a “balanced plan for stability” and asked, “those with more to contribute more”.  He started by setting out the changes to personal taxes. There were no surprises here as these had been trialled in the media over the last week. The […]

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. […]

US Tax Compliance For Foreign Trusts

When handling the US tax implications of trusts, particularly non-US trusts, there are a number of issues you must address: Is the entity a trust for US tax purposes? If the entity is a trust, is it a US (domestic) trust or a non-US (foreign) trust? If the entity is a trust, is it a […]

IRS Scams Investigations to include Pensions, Insurance & Digital Currency

For about 20 years now, the IRS has been annually publishing a ‘Dirty Dozen’ list of common taxpayer “scams.” The intent is to warn taxpayers, tax professionals, financial institutions, and financial advisors of abusive transactions, including bogus tax avoidance strategies as well as consumer-focused scams that target average taxpayers. The IRS identifies problem areas through audits, promoter […]

Maltese Pension Plans: The Malta/US Income Tax Treaty

Over the past decade, pension plans have been established and licensed in Malta with particular consideration given to US taxpayers. A number of these plans were designed to accept “rollovers” from foreign pensions plans owned by US persons – most notably from UK pension plans – combining the tax deferral benefits of a Qualifying Recognised […]

IRS Notice 2022-36 – Good News arrived in Short Packages

On August 24, 2022 the IRS issued Notice 2022-36 which provides failure-to-file penalty relief to many taxpayers who have late filed (or will late file) certain 2019 or 2020 tax returns. Included in this relief are the following income tax returns (not an exhaustive list): Form 1040 and 1040-NR Individual Tax Returns Form 1041 Tax Returns […]

Inflation Reduction Act: The Highlights

The Inflation Reduction Act was signed into law on August 16, 2022. The tax changes in the law are a part of the “deficit reduction” provisions, Washington-speak for “tax increases”. The most significant tax increases are primarily aimed at the largest corporations. The bill will impose a new minimum tax on corporations with an average […]

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