Corporate Tax Planning

Canadian Government Speaks to Washington About Thousands of Canadians Affected by U.S. Tax Reforms

CBC News reports that the Canadian government is in discussions with Washington about the impact of the Republican’s Tax Cuts and Jobs Act. Retroactive Repatriation Tax Part of the U.S’ $1.5 trillion tax overhaul package was a one-time retroactive Transition Tax, also known as the Repatriation Tax. This provision was intended to discourage U.S. multinational companies, such as Microsoft and Apple, from leaving their money in foreign subsidiaries. However, this provision is… Read More

Corporate Tax Planning

U.S. Treasury Department Introduces Guidance on “Pass-Through” Companies

Earlier today, the Treasury Department and the Internal Revenue Service (IRS) released long-awaited guidance on a key element of the Tax Cuts and Jobs Act, answering the many questions that were being asked by small business owners hoping to take advantage of major tax breaks included in the Republican tax reforms. Pass-Through Entities Today’s announcement was intended to provide additional clarity about the 20% deduction on income for owners and partners in… Read More

Personal Tax Planning

Democratic States Sue Federal Government Over Tax Reforms

Last month, New York, New Jersey, Maryland, and Connecticut sued the federal government, claiming that the Republican tax reforms brought in under President Trump unfairly single out high-tax Democratic states. The lawsuit, filed in the Southern District of New York, seeks to block the cap on deductions for state and local taxes and names the Internal Revenue Service and the U.S. Treasury Department as defendants. It seeks a court judgment ruling the… Read More

Personal Tax Planning

IRS Determines Donation of Artwork was a Completed Gift and Therefore Taxable

In a recent Private Letter Ruling, the Internal Revenue Service (IRS) considered whether a transfer of legal title and a remainder interest in artwork donated to a foreign museum accompanied by an agreement to transfer the balance of any retained interests after the death of the owner could be considered a completed gift for federal tax purposes.  The IRS decided that the transfer was a completed gift since the donor had relinquished… Read More

Tax Disputes & Litigation

Thousands of Americans May Be Denied a Passport Due to Unpaid Taxes

The IRS has begun to enforce a law passed by Congress in late 2015, which permits the State Department to revoke or deny passports to Americans who have significant tax arrears. More than 360,000 Americans who owe taxes are set to be affected. The Law Where an American has significantly delinquent tax debt (more than $51,000), IRC § 7345 authorizes the IRS to certify that debt to the State Department for action. The State Department… Read More