October 2017

Bye Bye John…but what about amnesty programs?

As expected, IRS Commissioner John Andrew Koskinen will step down in November.  It is expected that this may have implications for 2 key offshore voluntary compliance programs that we cover for many of our international clients. These are – 1. The streamlined initiative and 2. The OVDP http://www.derrenjoseph.com/2015/02/streamlined-foreign-offshore-procedures.html Note: The above reference link was live on […]

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Tax Court Declines to Follow Rev. Rul. 91-32 – Important Development for Foreign Investors!

On July 13, 2017, the U.S. Tax Court (Tax Court) issued a 55-page opinion rejecting the long-standing position of the Internal Revenue Service (IRS) as outlined in Revenue Ruling 91-321 concerning the sale by a foreign person of an interest in a partnership that is engaged in a U.S. trade or business for U.S. federal

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