The Section 965 Transition Tax

Jason Freeman International Tax, Tax Reform, Uncategorized Leave a Comment

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The Tax Cuts and Jobs Act of 2017 enacted a number of important tax-law changes.  Few changes are more notable than those contained in the international tax provisions. Perhaps chief among the international tax changes was the Section 965 “transition” tax—a.k.a. the “deemed repatriation” tax.   Section 965 generally requires that shareholders—as defined under section 951(b) of the I.R.C.—pay a “transition” …

The Current Federal Tax Treatment of Cryptocurrency

Jason Freeman and Jason Carr Bitcoin, Crytpocurrency Leave a Comment

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In 2014, the IRS announced that the use of convertible virtual currency to pay for goods or services in a real-world transaction has tax consequences.[1]Those consequences may result in a tax liability for the consumer. As a result—particularly in light of the IRS’s efforts to crackdown on failures to report cryptocurrency transactions, see here and here—it’s important to understand how cryptocurrency …

Tax Reform is Here: A Brief Primer on the Key Business Provisions

Jason Freeman Tax Reform Leave a Comment

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Just before the turn of the new year, Congress passed—and the president signed—the Tax Cuts and Jobs Act of 2017 (“TCJA”).  The TCJA represents the most extensive rewrite of the U.S. tax code in over 30 years.  The new act contains a number of important provisions that will impact business tax planning for years to come.  Below are some highlights …

Last Call: The IRS Will Soon Close the Offshore Voluntary Disclosure Program, Leaving a Limited Window to Obtain Criminal Amnesty

Jason Freeman OVDP Leave a Comment

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The IRS recently announced that it will officially close the Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018.  Its announcement serves as a “last call” for taxpayers who have willfully failed to report foreign assets or income—a last opportunity to come forward under the terms of the OVDP, which provides for criminal amnestyand other protections.  After September 2018, the …

Bigger Tax Liabilities, Better Installment Agreements

Zach Montgomery Installment Agreement, Uncategorized Leave a Comment

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If you are an individual taxpayer, you may have outstanding tax liabilities owed to the IRS. Even worse, penalties and interest continue to accrue, and the total liability grows more and more. This can obviously create anxiety on the taxpayer’s part, especially if those liabilities start to approach six figures. Fortunately, the IRS has expanded its test criteria for streamlined …

The Taxation of Hard Forks

Jason Freeman Bitcoin, Blockchain, Crytpocurrency Leave a Comment

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What are the tax implications of a cryptocurrency Hard Fork?  Does the holder of a cryptocurrency that undergoes a Hard Fork realize taxable income? If so, how does one determine the amount of the income and when, exactly, it is received?  These are not easy questions to answer. What is a Hard Fork? A Hard Fork—sometimes referred to as a “Chain …

Your Sins Are Forgiven: The Texas Tax Amnesty Program and Voluntary Disclosure Agreements

Zach Montgomery Tax Amnesty, Texas Tax Leave a Comment

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Former Supreme Court Justice Hugo Black once said, “The United States has a system of taxation by confession.” That statement is true at the federal level as well as the state level. In fact, the Texas government relies on its citizens to “confess” their franchise tax, sales and use tax, and other tax obligations through required reports and payments. However, …

The Limits of the Accountant-Client Privilege

Jason Freeman and Alex Aills Privilege Leave a Comment

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The accountant-client privilege, commonly referred to as the tax practitioner privilege, is codified in section 7525 of the Internal Revenue Code. However, before you put much stock in the privilege, a word of warning: courts have interpreted the accountant-client privilege to be extremely limited in scope. For example, it does not apply in state court matters or in criminal matters, …

The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

Jason Freeman and Spencer Banks FATCA, FBAR, Offshore Tax, OVDP Leave a Comment

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The Paradise Papers represent the latest large-scale leak of financial documents believed to link thousands of companies and individuals to hidden offshore accounts and secret tax havens.  The leak was massive, totaling some 1,400GB of data—that translates to an estimated 13.4 million documents covering a period from 1950 to 2016.[i]Nearly half of the leaked documents come from corporate registries in …