On February 27, 2023, the Supreme Court of Finland set a new precedent (KKO:2023:15) in their ruling concerning the application of penalties for tax evasion (tax fraud), when private individuals fail to report investment income from foreign sources on their Finnish income tax returns.
With the global economy we live in, it is important for Fund Managers to have an appropriately structured fund if they plan to have foreign investors. Too often, the fund structure is not tax efficient for the foreign investor. If the fund is not structured to accommodate foreign investment, why should a foreign investor consider investing in the fund?
CFOs and General Counsel of multinational corporations (non-U.S. parent) with operations in the United States face complex tax implications that must be planned for on a global basis and not make decisions solely based on the U.S. tax implications. Too often, the U.S. advisor will ignore the tax …
CFOs and General Counsel at U.S. multinational corporations are confronted with complex international tax that requires comprehensive global tax planning to reduce the global effective tax rate. Without a comprehensive strategy that considers not only the tax implications of the country where …
The after-tax proceeds of the sale of a business is of the utmost importance to sellers. Too often sellers agree to holdbacks or a reduction in purchase price for alleged tax issues raised by the purchaser during due diligence where the purchaser bears no actual risk.
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.
Taxes play an important role in the structure of a fund. There are various categories of investors that have different tax implications which will impact the structure of a tax efficient fund. One such group of investors are tax-exempt investors and the planning around Unrelated Business Income Tax (“UBIT”)…
For calendar years beginning after December 31, 2022, the third-party payment organizations are required to report payments in settlement of third-party network transactions with any participating payee that exceed a minimum threshold of $600 in aggregate payments, …
We hope you and your family are healthy, safe, and enjoying the holiday season to end 2022. We would like to take this opportunity to update you on exciting developments at Klug Counsel PLLC. We are excited about new members and practice areas that have been added to the firm and the creation of a related entity that will allow us to better serve our clients with accounting and finance support.
Every year, the estate and gift tax “basic exclusion amount” (commonly known as the “estate and gift tax exemption amount”) is adjusted for inflation. The Tax Cuts and Jobs Act passed in 2017 doubled the estate and gift tax exemption amount from $5 million to $10 million, adjusted for inflation. The amount is set to go back to $5 million, adjusted for …
On August 16, 2022, President Biden signed the Inflation Reduction Act into law. As part of the significant changes made by this legislation, the IRS will receive a budget increase of nearly $80 billion over the next ten years to improve four areas: enforcement, operations support, business system modernization, and taxpayer…
Treasury and the Internal Revenue Service (“IRS”) have finalized regulations that eliminate the requirement that an Internal Revenue Code (“IRC”) 754 election statement to adjust the basis of partnership property be signed by one of the partners of the partnership to be valid.
