THE TIME IS NOW: TAX AMNESTY OPTIONS, GILTI AND THE TRANSITION TAX
Even after the closing of the Offshore Voluntary Disclosure Program (OVDP) there are very attractive options for taxpayers to become compliant with their taxes and
Foreign Earned Income Exclusion – Housing Costs
The foreign earned income exclusion allows for Americans living and working abroad to exclude earned income, up to $107,600/person for 2020. To be eligible for
The Severe Penalty of Not Reporting Foreign Gifts and Inheritances
When dealing with international taxation there are many complex laws that can cause unexpected tax; however, the most severe and surprising situations often come from
Partner Josh Maxwell to Present at Asia Forum 2020
We are honored to have Partner Josh Maxwell as a panelist for two separate sessions at the virtual Estate Planning and Wealth Succession Asia Forum
Transition Tax: Heed the IRS Warnings
In 2017, certain taxpayers were subject to a one-time tax on earnings in controlled foreign corporations under Section 965, also known as the transition tax.
GILTI High Tax Exception Provides Administrative Relief for Many Taxpayers
As we have detailed many times, the transition tax and GILTI were two tax laws that were not designed for individual taxpayers. Therefore, much of
IRS Releases Draft International Forms for Partnerships
Despite claims of attempting to simplify compliance, in recent years, forms and compliance for international reporting has become much more detailed and complicated. In keeping
Webinar: GILTI and Transition Tax
Below is the link to our most recent webinar on GILTI and the Transition Tax. Thank you to AMCHAM Thailand for hosting! Click here for
AMCHAM Thailand Webinar: GILTI and the Transition Tax
Following up on our blog “GILTI and the Transition Tax: How, Why and Moving Forward,” HMLLP Partner Josh Maxwell will be presenting on these topics
GILTI and the Transition Tax: Why, How and Moving Forward
In this extended blog we explain the policy problems with these new tax laws, how to address them, and offer some suggestions for the future.
IRS: USMCA Replaces NAFTA in U.S. Tax Treaties
Once it enters into force, the USMCA will replace NAFTA. Since many U.S. tax treaties make reference to NAFTA, it was unknown if this would
New NOL Rules and the Transition Tax
Between the Tax Cuts and Jobs Act and the coronavirus, there have been many unique tax situations lately. It was only a matter of time