With its ruling n. 975 issued on January 18, 2018 Italy’s Supreme Court held that the transfer of an asset (real estate property) to an irrevocable trust falls outside the scope of Italy’s registration, cadastral and mortgage taxes (transfer taxes), charged at the aggregate rate of 10 percent, on the theory that it is a transitory step before the final transfer of the property to the beneficiaries of the trust actually occurs, at which time the transfer taxes should apply.

The ruling is consistent with a previous decision of the Supreme Court on the same issue, that is, ruling n. 21614 of October 26, 2016 (which we also commented upon on this blog). Read More

This webinar will provide tax counsel and advisers with a comprehensive guide to the tax and investment planning challenges and opportunities for high net worth foreign clients seeking to immigrate to the United States. The panel will discuss strategies for minimizing the U.S. tax impact of foreign-source ordinary and capital income prior to establishing tax residency in the U.S., detail the EB-5 program for nonresidents seeking to establish permanent residency through investment in the U.S. economy, and outline the tax issues that can arise from participating in a regional center. Read More

Tax credit systems are in place to let tax payers deduct a certain amount from their tax liability to the state or federal government based on different programs. One such initiative is the American Opportunity Tax Credit, or commonly known as AOTC. This tax credit system is designed specifically for college going students, allowing them to settle their college costs via tax credits. AOTC is much more beneficial when compared to tuition deduction since it allows for an actual reduction in taxes that you owe to the government. But there are certain eligibility criteria that one must meet to be able to benefit from this system. Read More

Yet there are many people who are contemplating not filing this year because they didn’t file last year. Taxation Solutions is a team of professionals that frequently encounters clients who, for various reasons, have not filed tax returns for one, two, or several years.

Believe me, you are not alone. There are thousands of people who haven’t filed in multiple years. But, let me tell you, you’ll enjoy getting a good night’s sleep once you get back on track with the IRS. Most people don’t realize the energy required to carry the burden of delinquent taxes. We are devoted to helping taxpayers make things right with the IRS. Read More

WASHINGTON –– The Internal Revenue Service is reminding victims of Hurricane Maria in the U.S. Virgin Islands and in the Commonwealth of Puerto Rico that filing and payment activities have been further postponed beyond Jan. 31, 2018.

The IRS extended tax deadlines for affected individuals and businesses until June 29, 2018, for the following localities:

  • In the U.S. Virgin Islands (starting Sept. 16, 2017): Islands of St. Croix, St. John and St. Thomas.
  • In Puerto Rico (starting Sept. 17, 2017): In any of the 78 municipalities.

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The Tax Cuts and Jobs Act (“TCJA”) has resulted in many changes in the tax laws. One little-noticed change affects trade-ins of vehicles uses for business. Let’s go over the tax changes for business vehicle trade-ins.

Old Tax Law: Tax-Deferred Exchange of Trade-In Business Car

Until 2017, you could do a tax-deferred exchange of a business vehicle. This was also called a Section 1031 exchange. With such an exchange, there would be no tax due on the sale of your trade-in. Read More

Living and working abroad comes with many exciting benefits. In addition to exploring new lands and learning about new cultures, expats often earn additional income beyond just their regular salary. Foreign earned income can come in many forms. In addition to the wages that are earned, those who are working outside the United States also must declare as income bonuses, tips, commissions, and the like.

It is also common for expats working overseas to have non-cash income as part of their employment package.
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WASHINGTON — The Internal Revenue Service today reminded taxpayers that income from virtual currency transactions is reportable on their income tax returns.

Virtual currency transactions are taxable by law just like transactions in any other property. The IRS has issued guidance in IRS Notice 2014-21 for use by taxpayers and their return preparers that addresses transactions in virtual currency, also known as digital currency. Read More

Tax Advisor’s – Your Thoughts On This Question Of The Week?

Do US citizens with U.K. personal pensions have to pay tax on the 25% portion that is not taxable in the U.K? The tax treaty suggests two different outcomes. Article 17.2 – yes and article 17.1 a and b – No.

I have seen some are now suggesting as these are periodic payments rather than the US definition of a lump sum then the relevant article is 17 1b and the US savings clause does also not apply and these payments are not taxable.

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In last week’s blog, we discussed how broad amnesties can blunt economic deterrence, but narrow amnesties or amnesty alternatives (e.g., amnesties that forgive only penalties before noncompliance is detected) do not necessarily have the same negative effects. We also cited research suggesting that those who participate in amnesties also tend to be people who made inadvertent errors (i.e., “benign” actors, rather than bad actors). Furthermore, without an amnesty, a sudden increase in penalties or enforcement is more likely to be viewed as unfair and erode trust for the government – a view that can erode voluntary compliance. Read More

WASHINGTON – The IRS, state tax agencies and the tax industry warned tax professionals to be alert to taxpayer data theft in the final weeks of the tax filing season. The Security Summit partners urged tax professionals to enhance their data safeguards immediately.

In recent days, the “New Client” scam has re-emerged, signaling ongoing attempts by cybercriminals to target tax professionals with spear phishing schemes. Read More

The following penalties apply to the person required to file Form 1042-S. The penalties apply to both paper filers and electronic filers. Late filing of correct Form 1042-S. A penalty may be imposed for failure to file each correct and complete Form 1042-S when due (including extensions).

The penalty, based on when you file a correct Form 1042-S, is: $50 per Form 1042-S if you correctly file within 30 days after the required filing date; the maximum penalty is $545,500 per year; if you file after August 1 or you do not file correct Forms 1042-S; the maximum penalty is $3,275,500 per year. If you intentionally disregard the requirement to report correct information, the penalty per Form 1042-S is increased.
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