Elections Forms and Filings Internal Revenue Code Nonresidents

Benefits of Election 83(b) for Nonresidents

An individual who receives property in exchange for the performance of services generally would report the fair market value of that property received as ordinary income, subjecting the individual imposition…

Business Tax Compliance

Compliance Assurance Process

The Compliance Assurance Process (“CAP”) is a program where a team from the Internal Revenue Service (“IRS”) works with participating taxpayers collaboratively to identify and resolve potential tax issues before…

Compliance Issues Internal Revenue Code Switzerland Tax Compliance

Justice Department Expecting to Collect over $1.36 billion from Swiss Banks

In the beginning of 2016, the Justice Department reported that it is expecting to collect over $1.36 billion from 80 Swiss banks and financial institutions that admitted to aiding U.S….

Entity Classification Internal Revenue Code Internal Revenue Service

Changes to the § 108 Exclusion Rule

Normally, under Internal Revenue Code § 61(a)(12), income from the discharge of indebtedness is includable in gross income, however, such income may be excludable from gross income under certain exceptions…

Business Compliance Issues Tax Compliance

Incorporation Transparency and Law Enforcement Assistance Act

Earlier this year, Representatives Carolyn B. Maloney and Peter King, both New York Congressmen, reintroduced legislation in the House of Representatives that would require disclosure of a corporation’s beneficial owner;…

Court Case FATCA Israel

Israeli High Court Dismisses FATCA Petition

A local branch of the U.S. Republican Party had filed a petition on January 11, 2016 with the High Court of Justice in Israel, Israel’s highest court, opposing FATCA laws. …

Cypriot

Cypriot Citizenship by Investment

The Cyprus government announced this week the lowering of investment thresholds to obtain Cyprus citizenship.  Previously an individual was required to invest either 5 million Euro if applying individually or…