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Income Taxation

  • Information Exchange With the United Kingdom Leads to Adjustment in Foreign Tax Credit Claimed

    By:
    Charles Ladas, CPA, and Joseph Neri, CPA
    |
    Oct 1, 2017
    As the global economy becomes more aligned, it is common for businesses and individuals today to have income and tax compliance issues in more than one country. With the complexity of varying tax regimes and the difficulty in monitoring offshore tax compliance, governments and taxing authorities around the world are looking for ways to collaborate and ensure taxpayers are paying their fair share, wherever they may be. 

  • Issues in Sun Capital Continue to be Top of Mind for Investment Funds

    By:
    LD Sergi
    |
    Jun 1, 2017

    In March 2016, the federal district court in Massachusetts (the “District Court”), issued a decision in Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund, 2013 U.S. App. LEXIS 15190 (1st Cir. 2013) (“Sun Capital”), holding that, for purposes of pension withdrawal liability under Title IV of the Employee Retirement Income Security Act of 1974 (ERISA), as amended by the Multiemployer Pension Plan Amendment Act of 1980 (MPPAA), two private equity funds were engaged in a trade or business and that they were under “common control” with the portfolio company such that they were jointly and severally liable for its pension withdrawal liability. 

  • Qualified Retirement Plan Design for Closely Held Businesses

    By:
    Andrew E. Roth, Esq., JD, LLM
    |
    May 1, 2017

    The primary goal of most employers in establishing any type of retirement savings program is to provide retirement income in a tax-efficient manner. The best way to achieve this is through a qualified retirement plan.

  • U.S. Tax Implications of Working Overseas – What You Need to Know

    By:
    Linda M. Bruckner, CPA
    |
    Mar 1, 2017
    Clients are often surprised when we inform them that although they will be living and working abroad, they must continue to file U.S. income tax returns and report their worldwide income as American citizens. 

  • Form 8865: Return of U.S. Persons with Respect to Certain Foreign Partnerships

    By:
    Mitchell Sorkin, CPA, MBA, PFS, CEA
    |
    Nov 1, 2016

    The purpose of Form 8865 is to report the information required under IRC section 6038 (reporting with respect to controlled foreign partnerships). This form also reports transfers to foreign partnerships and acquisitions, depositions, and changes in interest in foreign partnerships.

  • Does My Organization Have Unrelated Business Taxable Income?

    By:
    Robert Lyons, CPA, MST
    |
    Aug 1, 2016

    Unrelated business taxable income (UBTI) is a relatively simple concept: It represents activities conducted by an organization that are both (1) commercial and (2) not in furtherance of the organization’s exempt purpose. UBTI is based on the idea that when a nonprofit participates in commercial activities or exploits its exempt purpose, it would be competing at an unfair advantage with for-profit entities because, as a nonprofit, it generally does not pay taxes on its income. 

  • Examining the Nuances of New York Income Taxation of Trusts

    By:
    Catherine B. Eberl, JD
    |
    Feb 1, 2016
    Just like a resident individual, a New York resident trust is subject to New York income tax on all of its income. 
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