Federal Taxation

  • Pressure Builds on U.S. Taxpayers with Foreign Accounts

    By:
    Robert Barnett, CPA, JD, MS (taxation) and Renato Matos, JD, LLM (taxation)
    |
    Jun 1, 2014
    The Foreign Account Tax Compliance Act of 2010 (FATCA) has manifested outside the United States in recent months, as a result of an agreement announced on Aug. 29, 2013, between the U.S. Department of Justice and the Swiss Federal Department of Finance.
  • Opting Out of the IRS Offshore Disclosure Programs

    By:
    Eric L. Morgenthal, Esq., CPA, MS (Taxation)
    |
    May 1, 2014
    In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In the years that followed, the program was reintroduced and revised. Soon enough, thousands of practitioners started jumping on the foreign tax repair bandwagon. Many had no foreign tax experience or held limited knowledge of the foreign tax reporting and compliance requirements.
  • Guaranteed 10-Pay Whole Life Insurance Contracts

    By:
    G. Dean Goodwin, CLUT, AEPT
    |
    May 1, 2014
    Most advisors and clients utilize the benefits of life insurance for the traditional purposes of replacing income or providing liquidity to pay estate taxes through the income tax-free death benefit; however, permanent insurance is often perceived as being expensive and not providing a competitive rate of return compared to other asset classes. In order to provide policyholders with a sense of certainty, a number of mutual insurance companies have introduced guaranteed 10-pay whole life contracts that are contractually paid-up with 10 years of premium payments, regardless of dividend performance.
  • Feared PFIC Regs Get New Twist - Tax Stringer March 2014

    By:
    Lisa S. Goldman, CPA, and Thomas V. Ruta, CPA
    |
    Mar 1, 2014
    Late last year, the IRS released Temporary Regulation 1.1298-1T under IRC Section 1298(f) dealing with the complicated and troublesome rules surrounding passive foreign investment companies (PFICs). These new regulations require certain U.S. taxpayers who own shares in PFICs to report information about their investments on an enhanced Form 8621. The rules also have a complex history, and CPAs practicing in the international arena should pay close attention to the fine print.
  • The Nitty-Gritty of the ACA

    By:
    Daniel G. Mazzola, CPA, CFA
    |
    Mar 1, 2014
    The Affordable Care Act has received a lot of political attention, regarding the everything from controversial mandates to difficulties signing up to political opposition. But after a Supreme Court ruling, it’s undeniably here, and the more they know, the more CPAs can help their clients. Below is a brief summary and some examples of the major provisions of the ACA.
  • New Rules Reinstating Tax Exempt Status—Retroactively

    By:
    David A. Shuster, JD, LLM
    |
    Feb 1, 2014
    Has there been any good news lately for organizations that have had their exempt status automatically revoked for failing to file required annual returns or notices for three consecutive years? Well, 2014 began with a resounding "yes." A new Revenue Procedure will make it easier for organizations to regain their exempt status retroactively to the date of revocation so that, in effect, there is no lapse in exempt status.
  • Foreign Investment in the U.S.: A FIRPTA Introduction

    By:
    Alicea Castellanos, CPA, TEP
    |
    Jan 2, 2014
    They love us overseas. Yes, foreign investors want to buy U.S. real estate because of the weakening dollar, but there's more to it than that: The United States offers economic and legal transparency, backed by appropriate legal protections and a predictable regulatory environment. It’s no wonder that according to a 2013 survey from the Association of Foreign Investors in Real Estate (AFIRE), four of the five top global cities for investment are in the United States. But to take advantage of such desirable opportunities, investors, and the CPAs who serve them, need to familiarize themselves with the complex tax rules.
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