February 2019

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

Background –  https://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html https://www.mooresrowland.tax/2019/01/gilti-regime-guidance-answers-many.html     Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to GILTI attributed to individuals and trusts who own CFC stock […]

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If I Study and / or Teach in the US would I pay taxes on my World Wide Income?

President Reagan signed H.R. 4170 into law on July 18, 1984.  Thus, effective for tax years beginning after 1984, objective definitions of the terms residents aliens (“RAs”) and nonresidents aliens (“NRAs”) for Federal income tax purposes are incorporated into the Code. It is very important to note however, that the new definitions do not affect the

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Avoiding U.S. Controlled Foreign Corporation (CFC) status using Nominees?  You’re at risk with the IRS.

So often I speak with clients who were advised to use nominees to conceal their status as the UBO – ultimate beneficial owner. I cannot say this often enough.  It’s dangerous and it’s dangerous.  Banking is problematic, what if the nominee passes or becomes incapacitated, and most importantly – the IRS sees right through it. 

Avoiding U.S. Controlled Foreign Corporation (CFC) status using Nominees?  You’re at risk with the IRS. Read More »