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FOREIGN TRUST WITH U.S. JURISDICTION?

FRACTIONAL OWNERSHIP OF A FOREIGN ENTITY?

BEWARE!!!

The Tax Season for filing 2018 tax returns is now upon us and the full brunt of the Tax cuts and Job Act (TCJA) will occupy tax compliance by both the Taxpayers and the Tax Preparers.  One of the most staggering provisions of the TCJA is the situation where your client owns an interest in a foreign entity directly or indirectly through a tiered-entity-structure, (TES). 

The above threshold test will certainly raise eyebrows and compel the additional questioning to determine if you or your client falls into this catch-all provision.  A simple example of indirect ownership, TES, is as follows:

The above basic schematic shows how e

Hello and Welcome to my first News Letter on Matters That Will, Almost Certainly, Affect You in This New Year, 2019. I know that 2018 was a difficult year and now with the traumatic effect of the U.S. Government Partial Shutdown with the stock markets swings to record lows, we are facing a much high
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More End Of The Year 2018 Tax Planning: The IRS announced today that Tesla, Inc. has sold more than 200,000 vehicles eligible for the plug-in electric drive motor vehicle credit during the third quarter of 2018. This triggers a phase out of the tax credit available for purchasers of new Tesla plug-i
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INTRODUCTION:

For my clients residing in States with high State Income Taxes and/or high personal residential property taxes, the valued and yearly deduction of these taxes on your Itemized Deductions beginning in 2018 has had the unlimited ceiling crashing down to a total of $10,000 per year.

PART I.

What does this mean?

For 2018, all of your usual deductible itemized tax deductions are radically diminished in their treasured reduction of your overall U.S. Income Tax Liability. 

If you look at your form 1040, Schedule A for 2017 and calculate your total taxes paid, including but not limited to:

State Income Paid in 2017, State Income Taxes Withheld from your Wages and Pensions, Your State Estimated Taxes Paid f
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If you are considering the New IRS Voluntary Disclosure Program, what questions should you be asking of yourself and your Legal Counsel? On November 20, 2018, the U.S. Internal Revenue Service, (IRS) issued its Memorandum that addresses the process for all domestic and offshore voluntary disclosures
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Lets look at a traditional expensive method of shifting profits from your foreign company to you, the U.S. Shareholder. (Part I)

This is a very recent Tax Court Case, September 2018, where a husband and wife, named Barry and Rochelle Smith, were the grantors of two Domestic Grantor Trusts.  I will use some leeway to fill in areas not noted in the Tax Court Case itself that I believe is more probably than not as we move through this scenario.

Since the totality of this scenario has international entities and transactions, I would assume that the trusts were created outside of the United States, but has fulfilled the conditions of U.S. Treasury Regulations § 301.7701-7 that the trust is a domestic trust if the a court within the United States is able to exercise

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As income tax filing season approaches, the U.S. Commodity Futures Trading Commission (CFTC) is warning investors to be cautious of sales pitches touting “IRS approved” or “IRA approved” virtual currency retirement accounts. BACKGROUND: IRAs are retirement accounts that provide investors wit
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With nearly 10 million U.S. taxpayers facing a penalty for underpayment of estimated tax last year, you should plan ahead, understand the options and avoid the huge penalty when filing 2018 Tax Return! And time is moving so quickly you may already be in the unfortunate penalty provisions.

Those of us who fall into the following categories are very susceptible to these penalties:

1. Self-employed 2. Receiving other income, such as a. Interest, b. Dividends, c. Self-employment, d. Capital gains, e. Prizes and awards or f. Too little tax withheld from wages. You probably need to either: 1. Immediately begin making Estimate Tax Payment, 2. Immediately make a Lump Sum Tax Payment for 2018 3. Increase your withholding on Earnings 4. Increase withholding on Royalties, Capital Gai

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Is it possible at this late date? The new tax act of the Trump Administration, The Tax Cuts and Jobs Act, made significant changes for individuals, but the biggest were the loss of Itemized Deductions for high tax States, like California and New York, where Sales Tax, Real Estate Tax, State Income T