McKay Hartley

The story is a bit different if the §962 election was made to reduce tax payable on GILTI. The cost of the election is that the shareholder only gets to treat an amount equal to the actual US tax paid as previously taxed, so most of the dividend will be taxable. This may not make much of a difference, however, as any tax paid where the…[Read more]

This credit can be particularly useful to taxpayers who could be topic to double taxation (those who need to pay taxes to each the U.S. Most importantly for those with international accounts who’re considering becoming a member of the voluntary disclosure program, in saying the plea, the IRS CI Chief cautioned that the McCarthy prosecution is…[Read more]

For example, it applied a safe harbor for those who transact only limited business in South Dakota. The law said retailers with sales of $100,000 or less, or fewer than 200 instate transactions, were exempt. Additionally, South Dakota is one of more than 20 states to adopted the Streamlined Sales and Use Tax Agreement, requiring certain…[Read more]

See IRS Criminal Investigation Voluntary Disclosure Practice, for the most current voluntary disclosure procedures. Foreign account disclosure clients who are divorced, separated, and estranged from spouses. We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.

Failure­to­File Pen…[Read more]

The main two types of taxes a foreign U.S. business owner should be concerned about are income tax and sales tax. Those are two completely different, unrelated taxes.

Nonresident aliens cannot have had a green card at any time during the relevant tax reporting period. Also, they cannot have resided in the U.S. for more than 183 days in the…[Read more]