Internal Revenue Code Archives - Page 2 of 3

Bahamas Leak

Just months after the massive document leak known as the Panama Papers, 1.3 million files from the Bahama’s corporate registry has hit the internet in what is being referred to…

October 19, 2016

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…

October 19, 2016

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. …

September 22, 2016

Business Compliance Issues Elections Entity Classification Forms and Filings Internal Revenue Code

Proposed Regulations regarding Foreign-Owned Domestic LLCs

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…

July 6, 2016

Compliance Issues FATCA Forms and Filings Internal Revenue Code International Treaty U.S. Withholding

Changes to Form W-8BEN-E

Form W-8BEN-E Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities) is a form prepared by a foreign entity which must be provided to a…

July 6, 2016

Internal Revenue Code International Taxation International Treaty Tax Compliance

Stock Redemptions for Nonresident Aliens

The IRS treats a stock redemption as either a dividend or a capital gain. According to Internal Revenue Code § 302, if a stockholder’s equity interest remains relatively the same…

July 5, 2016

Business Entity Classification Foreign Tax Preparation Internal Revenue Code International Treaty

Foreign Investors in S-Corporations

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…

June 22, 2016

Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance

Form 3520 – Substituting the Foreign Grantor Trust Beneficiary Statement

Beneficiaries of Foreign Grantor Trusts will generally receive a Foreign Grantor Trust Beneficiary Statement detailing information for the tax year related to that trust. Question 29 of Part III of…

June 22, 2016

Internal Revenue Code U.S. Withholding

§ 1031 – Like Kind Exchanges

When selling a business or investment property, a taxpayer is generally subject to tax on ordinary income, capital gain, deprecation recapture and/or a Medicare surcharge (“Obamacare”). Paying these tax liabilities…

June 22, 2016

Foreign Tax Preparation Internal Revenue Code Internal Revenue Service Tax Compliance

Nonresident Aliens and the § 121 Principal Residence Exclusion

Internal Revenue Code § 121 provides taxpayers with an exclusion from gross income of up to $250,000 of gain on the sale of a taxpayer’s principal residence. A married couple…

June 22, 2016

Compliance Issues Internal Revenue Code Internal Revenue Service Tax Compliance

Form 8938 – New IRS Regulations Require Domestic Entity Filers

Pursuant to new guidance (T.D. 9752, RIN 1545-BM54) issued by the Department of Treasury under Internal Revenue Code § 6038D and effective as of February 23, 2016, the requirement for…

June 16, 2016

Internal Revenue Code Tax Compliance

Foreign Students and the Five Year Rule

It is not uncommon for foreign individuals from abroad to attend university in the United States on a F-1 Student Visa. In general, nonresident aliens who are present in the…

March 2, 2016

Category: Internal Revenue Code

Bahamas Leak

Changes to the § 108 Exclusion Rule

Israeli High Court Dismisses FATCA Petition

Proposed Regulations regarding Foreign-Owned Domestic LLCs

Changes to Form W-8BEN-E

Stock Redemptions for Nonresident Aliens

Foreign Investors in S-Corporations

Form 3520 – Substituting the Foreign Grantor Trust Beneficiary Statement

§ 1031 – Like Kind Exchanges

Nonresident Aliens and the § 121 Principal Residence Exclusion

Form 8938 – New IRS Regulations Require Domestic Entity Filers

Foreign Students and the Five Year Rule

Christopher J. Byrne PLLC

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