April 2020

Frequently asked questions about carrybacks of NOLs for taxpayers who have had Section 965 inclusions

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) amended section 172(b)(1) to provide for a carryback of any net operating loss (NOL) arising in a taxable year beginning after December 31, 2017, and before January 1, 2021, to each of the five taxable years preceding the taxable year in which the loss arises […]

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Treasury, IRS announce cross-border tax guidance related to travel disruptions arising from the COVID-19 emergency

  IR-2020-77, April 21, 2020 WASHINGTON — The Treasury Department and the Internal Revenue Service today issued guidance that provides relief to individuals and businesses affected by travel disruptions arising from the COVID-19 emergency. The guidance includes the following: 1. Revenue Procedure 2020-20 (PDF), which provides that, under certain circumstances, up to 60 consecutive calendar days

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Grantor Trust

Generally speaking, an arrangement will be treated as a “trust” (as opposed to some other type of entity) under the Internal Revenue Code (IRC), if it can be shown that the purpose of the arrangement is to vest in trustees responsibility for the protection and conservation of property for beneficiaries who cannot share in the

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Subpart F Income from CFC subsidiaries

I have previously discussed subpart F – https://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html https://www.mooresrowland.tax/2020/02/the-tax-cuts-and-jobs-acts-impact-on.html Consider first a fact pattern where a U.S. parent owns CFC1, which sells the stock of CFC2. 1. CFC2 was originally formed by CFC1, which invested $150 in the stock of CFC2. 2. CFC2 has incurred operating losses of $100 and has $50 of remaining basis

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Postpandemic Reality – Pumping the Brakes

Now let’s try to be realistic. This virus will not disappear.  Look out for on again, off again lockdowns. With global coronavirus cases growing daily, in March 2020, Harvard infectious disease experts published an article in the Harvard Gazette.  Modeling showed that — absent the development of a vaccine or other intervention — a staggered

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Evolution in the Economic Citizenship and Economic Residency Space

Take Aways: 1. A cycle of lock-downs and re-openings may become the new norm 2. Countries allow their citizens to return but sometimes long term residents have been denied re-entry 3. Therefore a Plan B for residency and / or citizenship is now a must for international entrepreneurs 4.  Typically the narrative around second citizenship

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Post Pandemic increase in Remote Working and Learning.

Take Aways: 1. Greater remote working and remote learning is one of the more obvious consequences of the pandemic 2. Like most of the other trends, it was on the upswing pre-pandemic but will accelerate post pandemic. Upwork’s “Future Workforce Report” predicts that 73% of all teams will have remote workers by 2028 and 75%

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This is not a 1930s style Depression – Ben Bernanke vs Ray Dalio

Take-Away 1. The debate over “recession vs depression” or “V shaped vs U shaped recovery” is somewhat academic.  All that matters to internationally mobile entrepreneurs, expats and investors is that the economic contraction will be “bad” 2. We need to prepare by answering questions that include –  –  Relatively speaking, which sectors and geographies will

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Entrepreneurship is dead.  Long live Entrepreneurship in the Post Pandemic World

Take Aways 1, There is no doubt that in the last couple decades, labeling oneself an “entrepreneur” has become “a thing”. 2. Cheap debt and easy funding has indeed made it possible for “entrepreneurs” to create “pre revenue” businesses.  Controversially, we have seen businesses with no clear plans for making a profit enjoy billion-dollar valuations.

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