The ERC was first introduced in March 2020 to help employers retain employees through the Covid-19 pandemic. The IRS has made it a priority to recover wrongly claimed refunds through the ERC. Given the ERC required…
The Employee Retention Credit (“ERC”) was first introduced in March 2020 to help employers retain employees through the Covid-19 pandemic. The Internal Revenue Service (“IRS”) has made it a priority to recover wrongly claimed refunds through the ERC.
Starting this year, most companies doing business in the US must report information about their beneficial owners (“BOI” or “BOI report”) to the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). This requirement is based on the Corporate Transparency Act (“CTA”)…
Target companies in mergers and acquisitions are often directed by the acquiror to change its tax classification preacquisition for U.S. tax purposes. There are several reasons that an acquiror may request the target company to
It is important for employers who made questionable claims for the Employee Retention Credit (“ERC”) to take immediate action to determine whether the ERC Voluntary Disclosure Program (“ERC VDP”) is their best compliance option. Since the…
We would like to take this opportunity to share some exciting developments at the firm that further our commitment to provide customized services to our clients.
U.S. citizens are subject to tax on their worldwide income no matter where in the world they reside.
As multinational corporations continue to expand their operations globally, they must navigate a complex web of tax regulations and laws. It is essential that they take a comprehensive approach to tax planning and not make decisions solely based on the U.S. tax implications.
U.S. citizens and U.S. tax residents (“U.S. Persons”) are taxed in the United States on their worldwide income no matter where in the world they reside. The U.S. taxes based on citizenship, which is different than almost all other countries in the world that tax based on residence.
The income of a foreign corporation is not subject to federal corporate income tax unless the foreign corporation has income that is effectively connected with a U.S. trade or business (or permanent establishment as provided in an applicable tax treaty) or consists of certain types of U.S. source fixed …
Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best security, most privacy, best income, lowest taxes, and lowest costs. While the extremely wealthy often utilize these trust structures, they are in no way limited to the extremely wealthy and are often used by high-net-worth individuals (i.e., more than a million in assets). For many, it is also important to diversify their asset holdings outside their country of residence. Powerful trust laws, tax savings, asset protection and privacy, as well as solutions to political and regulatory concerns, all combine to make the U.S. the trust situs of choice.
Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best security, most privacy, best income, lowest taxes, and lowest costs. While the extremely wealthy often utilize these trust structures, they are in no way limited to the extremely wealthy and are often used by high-net-worth individuals (i.e., more than a million in assets). For many, it is also important to diversify their asset holdings outside their country of residence. Powerful trust laws, tax savings, asset protection and privacy, as well as solutions to political and regulatory concerns, all combine to make the U.S. the trust situs of choice.
