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. […]
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Tag: IRS
U.S. Taxation of U.S. Citizens Living Abroad, Including Planning Opportunities
U.S. citizens are subject to tax on their worldwide income no matter where in the world they reside […]
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U.S. Taxation of Foreign Nationals Working in the U.S., Including Planning Opportunities
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. […]
Comprehensive Approach to Tax Planning for U.S. Multinational Corporations
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. […]
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The Importance of Not Overblocking for UBIT
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”). A common planning strategy for UBIT is placing a blocker corporation in the structure. If the blocker corporation blocks more than the UBIT, the tax-exempt investors will have their investment earnings reduced unnecessarily. […]
IRS Delays Implementation of $600 Threshold for Third-Party Payment platforms’ Forms 1099-K
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, regardless of the number of such transactions. […]
IRS will Prioritize Enforcement Under $80B Funding: Large Business and International Division
Prepared by Arturo Meza, Foreign Associate at Klug Counsel 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, […]
IRC §754 Election: Partner Signature No Longer Required for Partnership Basis Election
Prepared by Gina Lee, Senior Associate at Klug Counsel 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. To understand the […]
Crypto Brokers and Exchanges Informational Reporting Likely Delayed
The Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) are likely to delay a January date for crypto brokers and exchanges to begin tracking and reporting data such as customers’ capital gains and losses. The move will delay when the IRS receives the same kind of data from crypto transactions as it receives for […]
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Deducting Cryptocurrency Losses
Many investors in cryptocurrencies have seen their investments lose significant value in recent months. U.S. taxpayers who have losses from their digital asset investments or have had them stolen can deduct losses. For individual taxpayers, typically the loss from the sale of crypto assets will result in a capital loss. Capital losses can offset capital […]