Latest Articles

  • U.S. Announces Greater Scrutiny of Foreign-Owned LLCs: Is Peer Pressure a Motivator?

    By:
    Alicea Castellanos, CPA, TEP, N.P. and Jack R. Brister, TEP
    |
    Aug 1, 2016

    The United States and other jurisdictions have spent a decade trying to identify owners of foreign corporations. Now, a five-year-old report by the Organization for Economic Cooperation and Development (OECD) might have served as an impetus for a U.S. proposal regarding disclosure requirements for limited liability companies (LLCs). 

  • Form 926: Return by a U.S. Transferor of Property to a Foreign Corporation

    By:
    Mitchell Sorkin, CPA, MBA, PFS
    |
    Aug 1, 2016

    This article is the first in a series of articles explaining various IRS forms that relate to the reporting of foreign transactions.

  • Is It Debt or Equity? A Survey of the Proposed Section 385 Regulations

    By:
    James J. Wienclaw, CPA
    |
    Jul 1, 2016
    The fundamental question investors address when capitalizing a business is how it should be funded—with debt, equity, or a combination of both. Considerations can vary widely depending on the level of risk an investor is willing to take or the desired tax treatment.
  • New Seller Due Diligence Responsibilities After the Midco Cases?

    By:
    Ellen S. Brody, CPA, JD, Esq. and Vivek A. Chandrasekhar, JD, Esq.
    |
    Jul 1, 2016
    In the post-General Utilities world, shareholders have looked to dispose of their interest in C Corporations with appreciated assets in a way that would avoid the double taxation arising on a sale of assets followed by a liquidating distribution to the noncorporate shareholder. 
  • U.S. Real Estate Beckons to Foreign Investors in Wake of FIRPTA Revisions

    By:
    Alicea Castellanos, CPA, TEP, NP and Jack R. Brister, TEP
    |
    Jul 1, 2016

    Changes to U.S. tax rules that were signed into law in December have important implications for foreign entities seeking to invest in the U.S. real estate market. This includes both additional disclosure requirements and provisions that may increase the tax efficiency of certain assets.

  • A Few Words About Estate Planning and Trustee Engagements

    By:
    Ron Klein, JD, CFE
    |
    Jul 1, 2016

    Thirty years of protecting CPAs from malpractice risks has shown that every CPA is safer if they understand the risks they are facing. In no type of engagement is this truer than in estate planning and trustee engagements. And the reason for this is clear: hindsight!


  • Mortgage Interest Tax Deduction

    By:
    Daniel Lahage, CPA
    |
    Jun 1, 2016
    During every election cycle, a set of tax proposals set forth by candidates become topics for debate. Whether or not each candidate will actually be able to implement that tax policy is another question. 
  • Tax Haven, USA

    By:
    Erica Rubin, CPA, CGMA
    |
    Jun 1, 2016

    International tax structuring and cross border planning has always been a complex and evolving process. The massive leak at Mossack Fonseca, the Panamanian law firm responsible for setting up countless offshore companies, along with the U.S. Treasury Department’s challenge to the corporate inversion “loophole” have brought forth issues that will again challenge the status of tax havens in the global marketplace.

  • Coming to America – Love, Marriage and Immigration

    By:
    Carole M. Bass and Rebecca A. Provder
    |
    Jun 1, 2016

    In the 1988 hit comedy, Coming to America, Prince Akeem, heir to the throne of Zamunda, flees his home country to escape an arranged marriage. He comes to the United States to find his queen, a woman who will love him in spite of his vast wealth and title. Sure enough, he finds Lisa McDowell, heir to the McDowell’s Restaurant fortune.

  • Foreign Trust Reporting: Substance Over Forms? I Think Not

    By:
    Alicea Castellanos, CPA, TEP, NP and Jack R. Brister, TEP
    |
    Jun 1, 2016
    In a world dominated by data, the IRS’s role in data collection continues to expand. No longer is the agency’s sole focus domestic income tax reporting, collection, and enforcement; rather, today’s IRS is responsible for activity that occurs beyond U.S. borders and disseminating an array of information. 
     

Tax Quote

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- Mark Twain

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*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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