Tax News

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 the guidance and regulations have little impact or relevance to individual taxpayers or taxpayers with simple foreign structures.  The new high tax exception is no different as most of the […]

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 with this theme, the IRS has released drafts of new forms to allow partnerships to report international items to partners with greater detail. At first glance, for many taxpayers it […]

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 recorded event.

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 in collaboration with AMCHAM Thailand. For more information or to attend, click here.

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. GILTI and the Transition Tax: Why, How and Moving Forward

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 cause any issues with these provisions, and despite a recent IRS clarification, it is probably still a bit unknown. References to NAFTA appear in treaties even outside the U.S., Mexico, […]

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 before these started to interact and cause problems.  As part of the coronavirus provisions under the CARES Act, the IRS allowed for certain NOLs to be carried back.  This carryback […]

Many U.S. international tax laws are determined based on time spent in or out of the U.S., as well as what type of activities and the amount of activities performed in the U.S.  With the coronavirus greatly affecting the ability to travel, taxpayers could have been forced into unfavorable situations through no fault or desire […]

Today, IRS Notice 2020-23 widely expanded the coronavirus extensions and clarified some very key issues.  In general, most, if not all, tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020.  However, for specific forms not mentioned below it is necessary […]

The Franchise Tax Board has updated its Coronavirus FAQ page with the following information: The Recovery Rebate Payments from the IRS are not taxable in California The additional $600/week of unemployment benefits is not taxable in California The modifications to the net operating loss rules for the IRS do not apply to California California will […]