Voluntary Disclosure Post OVDP

Now that the IRS has closed the Offshore Voluntary Disclosure Program, it has issued new guidance on how voluntary disclosures should be handled going forward.  See full text here:  OVDP Process Post Sept 2018 Unfortunately, the memo does not provide much information or any unexpected relief.  Basically, it is only a restatement of the current voluntary […]

Transition Tax: What’s Next

Although it feels like we just finished addressing the transition tax, and for many people we did, it has been roughly a year since it was implemented.  Despite having a year for clarification, there is not a lot of helpful information from the IRS at this point.  However, we must do our best to work […]

Wayfair: A New World for Online Sellers

Over the summer, the Supreme Court issued its decision in the pivotal case of South Dakota v. Wayfair, Inc.  It will take some time to see the full effects, but for now it appears e-commerce may have taken hit as states prepare to move in and collect sales tax from online retailers. Before Wayfair, the […]

Don’t Be Scared, It’s Only Reporting

A common misconception is some variation of clients thinking it will be a problem if they invest through the Cayman Islands or open a bank account in Switzerland.  With the fall of the Swiss banks, the stigma of stories such as the Panama Papers, and the global move towards transparency through FATCA and CRS, it […]

Recent Trip to Hong Kong – What I Learned

At the end of September, I spent two weeks in Hong Kong, which sandwiched in the typhoon, making presentations and meeting with contacts and clients.  As always, I wanted to share some of the pictures, but also some of the common situations I encountered. Proactive v. Reactive – There has been a shift and now […]

FDII and GILTI: A Quick Summary

As many taxpayers move past the transition tax and other provisions that needed to be addressed immediately, next on the list are the foreign-derived intangible income deduction (FDII) and the global intangible low-taxed income (GILTI).  Despite having similar terms and measurements, these two new laws are actually very different, and this is likely what is […]

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