February 2020

US Reporting of Accounts in Digital / Challenger Banks (FBARs)

It’s #taxseason and for the first time, there is a question on #crypto #cryptocurrency But we do not get as many questions on #bitcoin as we do on #challengerbanks.  The definition of challenger banks is wide but I’m including service providers like #transferwise #revolut #YouTrip #InstaReM #Monzo #PayPal #TIAA etc The questions often posed is

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Employee or independent contractor: Whats the difference?

  When I speak with location independent entrepreneurs and expats, the issue of employee vs contractor frequently comes up. There is no uniform test to distinguish employees from independent contractors. Government agencies such as the IRS, the U.S. Department of Labor (DOL), and the National Labor Relations Board (NLRB) each look at their own set

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Being Location Independent within the EU

I previously wrote on the trend towards the EU taxing its non resident citizens – https://www.mooresrowland.tax/2020/01/the-eu-taxing-non-resident-citizens.html Similarly, we are frequently approached by location independent international entrepreneurs in the EU who would like to remain in the EU. To understand the freedom of establishment, we refer to Articles 26 (internal market), 49 to 55 (establishment) and

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The Tax Cuts and Jobs Acts Impact on Cross-Border Transactions

We’ve wrote alot about TCJA in general and GILTI in particular – https://www.mooresrowland.tax/2019/02/gilti-rules-particularly-onerous-for.html https://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html https://www.mooresrowland.tax/2018/12/the-2017-tax-cut-and-jobs-act-and.html https://www.mooresrowland.tax/2019/11/switching-from-s-to-c-corporation.html https://www.mooresrowland.tax/2020/01/foreign-companies-unintentionally.html https://www.mooresrowland.tax/2019/01/gilti-regime-guidance-answers-many.html Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory provisions, reinforcing calls

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