Nonresidents and Taxation of Online Personal Services
While taxpayers who run online businesses from the United States are generally subject to income tax and state sales tax (depending on the nature of the business, the primary location…
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…
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;…
Under current regulations, spanning from Treas. Reg. §§ 301.7701-1 through 301.7701-3, a domestic limited liability company (“LLC”) organized under the laws of the United States, with only one member is…
Pursuant to Internal Revenue Code § 1361, there are certain restrictions to qualify for S-Corporation status; one of which is that a shareholder cannot be a nonresident alien. If a…
S-corporations, Nonresident Aliens and Community Property Laws
An S-corporation is a business entity in which all of the corporate income, losses, deductions, and credits each year are passed through to the shareholders for federal tax purposes. Shareholders…
Recent Changes to IRC § 1202 Small Business Stock Gains Exclusion
In December 2015, the Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) was passed by Congress and signed into law and with it made certain tax breaks permanent,…
