IRS Offers New Guidance on New Tax Benefit

The Internal Revenue Service has issued Notice 2018-97 offering guidance on a recent tax law change that allows qualified employees of privately-held corporations to defer paying income tax, for up to five years, on the value of qualified stock options and restricted stock units (RSUs) granted to them by their employers.  The tax law change was included […]

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What is GILTI?

The Global Intangible Low-taxed Income (GILTI) is a new provision, enacted as a part of the Tax Cuts & Jobs Act (TCJA) tax reform legislation. The provision defines GILTI income as the amount of income earned by a U.S. foreign subsidiary above a certain threshold amount. Under the TCJA, a U.S. person (includes U.S. individuals,

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Do I need to worry about “One Time Transition Tax”?

As of January 1, 2018, the 2017 Tax Cuts & Jobs Act (TCJA) changes the taxation regime for U.S. multinational corporations. The international provisions in TCJA introduce a new territorial system for the taxation of foreign company income.  Before these new tax provisions take effect, the new law imposes a mandatory one-time tax (the “Transition

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How Will the New Territorial Tax System Affect U.S. Competitiveness?

Introduction The recently enacted 2017 Tax Reform Act embraces major sweeping changes to US international tax rules. President Donald J. Trump has endorsed large changes to the federal tax code, and as per sources, the steps such as lowering rates for individuals and corporations, and further changing the taxation of overseas profits, will increase the

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What You Need to Know About The New Expat Tax Laws on Offshore Income

President Trump on December 22 signed and signaled a new Law that focused on amending changes in specific regions of the prevailing US law like Tax cuts related to businesses, individual, multinationals and most importantly Jobs. One of the primary focus was on foreign and offshore incomes that are earned, and multinational corporations and the

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Some US persons are to receive IRS letters about their Swiss bank accounts

The IRS is set to send out letters in early 2018 to get financial information from certain U.S. people who has or had bank accounts in Swiss banks with delinquent filings and who signed waivers allowing the banks to hand over information to the IRS under FATCA (a Justice Department Program – DOJ). Under the

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