Under Section 6038 of the Internal Revenue Code, some U.S. taxpayers must comply with information reporting requirements regarding their interests in certain foreign corporations and partnerships. In the recent case of Alon Farhy v. Commissioner, the U.S. Tax Court was tasked with deciding whether the IRS can assess failure-to-file penalties in relation to Sec. 6038. Forms Not …
Business disputes arise every day. For example, a supplier violates a provision of an exclusivity contract, a publisher infringes on a writer’s copyright or a competitor steals a trade secret. These wrongdoings typically result in one party losing money. It’s up to the legal system to restore order and award economic damages. Here we discuss some …
Fraud committed by employees, management, vendors or customers can happen to any business. And if it does, it can take years to recover from the financial losses and reputational damage. In some cases — especially those involving small companies that lack the cash reserves to cushion the blow — a fraud incident can shut down a …
Many retirees have seen their Social Security benefits increase in 2023 due to a cost-of-living adjustment that was higher than in past years. Further increases are expected for 2024. While more benefits are welcome, they could mean more income taxes on those benefits for some recipients. The Social Security Administration (SSA) estimates that more than …
The IRS historically has considered construction a high-risk compliance industry because of its potential for cash transactions, underreported income and worker misclassification. What’s more, as the tax agency rolls into the future under new leadership, with improved technology and a boosted workforce, many business pundits are keeping an eye out for a rise in audit …
If you aren’t married and have no children, you may think you don’t need an estate plan. But nothing could be further from the truth. Even single people should have an estate plan. Unlike with married couples, there could be no specific person who can legally make medical decisions for you should you become incapacitated. …
If you’re philanthropically inclined, establishing a charitable remainder trust (CRT) is worth considering. These irrevocable trusts provide a variety of tax and financial perks. Plus, unlike some other tax planning tools and strategies, CRTs can benefit from today’s rising interest rates. How CRTs Work A CRT is an irrevocable split-interest trust that pays a specific …
The IRS recently announced through Notice 2023-31 that it will provide a longer transition period for the documentation requirement when the single-country exception to the source-based attribution requirement in the proposed foreign tax credit regulations is finalized. The amended transition period will provide that the required license agreement must be executed no later than 180 …
The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) in September 2022 issued final regulations implementing the Corporate Transparency Act (CTA). The law requires certain business entities created or registered to do business in the United States to report identifying information about their “beneficial owners” to FinCEN. Recently, FinCEN issued frequently asked questions (FAQs) on these …
When it comes to fighting fraud, there’s a tried-and-true statistical precept that remains as relevant and widely accepted as ever. “Benford’s Law” is often used by forensic accountants to spot dubious digits — and catch even the most sophisticated thieves. Historical Background The principle is named for Frank Benford, a physicist who noted in the …