Share to Twitter Share to Linkedin Elodie Lamer and Nana Ama Sarfo of Tax Notes discuss the tax implications of golden visas and passports, which allow affluent foreigners to receive residency or citizenship in exchange for a minimum level of investment. This transcript has been edited for length and clarity. David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International . This week: good as gold. The idea of immigration often conjures up black and white images of huddled masses on ships in New York Harbor. People seeking new opportunities to make their fortune. But what happens for people who've already made their fortune and don't have time to wait in line for the normal process? And what about the growing class of remote workers who don't need to be physically anywhere? This week, we're talking about golden passports with Tax Notes reporter Elodie Lamer and Tax Notes … [Read more...] about First-Class Tax Opportunities: Golden Visas And Passports
State tax notes
Reviewing Standard Of Review After Tax Court’s Coca-Cola Opinion
Share to Twitter Share to Linkedin Every U.S. Tax Court opinion in an IRC section 482 case dutifully recites some variation of the necessary incantation: The IRS has broad discretion in applying section 482 , and its determinations must be upheld unless the taxpayer can establish that the IRS abused its discretion by making adjustments that are “arbitrary, capricious, or unreasonable.” However, a substantive discussion of how that vague formulation should be applied in transfer pricing cases is much harder to find, and the Tax Court’s decades of manifest refusal to defer to the IRS’s section 482 interpretations compounds the mystery and confusion. Before the Tax Court issued its opinion in Coca-Cola Co. v. Commissioner , 155 T.C. 145 (2020), the most substantive guidance on the matter arguably came from a 1935 case that predates section 482 and the Tax Court itself. In Asiatic Petroleum Co. v. Commissioner , 31 B.T.A. 1152, 1157 (1935), aff’d … [Read more...] about Reviewing Standard Of Review After Tax Court’s Coca-Cola Opinion
IRS Kills Tax Free Crypto Exchanges? Not Hardly
Share to Twitter Share to Linkedin In 2014, the IRS said crypto was property. Five years went by, and the next thing the IRS said was that hard forks were taxable. How about swaps of crypto for crypto guidance? Not so much. There is no official guidance, although we all know that by statute, 1031 now applies only to real property. How about for 2017 and prior years? It just isn’t clear if you could claim 1031 exchanges on your 2017 taxes . That is why the world sat up when someone from the IRS said–at a conference–that 1031 didn’t apply even to those old years. Is that official guidance? Not hardly. An IRS person said the IRS view was “no” on 1031 for crypto. Suzanne Sinno, an attorney in the IRS Office of the Associate Chief Counsel, made the remark at an American Institute of CPAs conference November 13, 2019. She worked on the recent cryptocurrency guidance the IRS issued , but this was not an official announcement, nor was it “authority” … [Read more...] about IRS Kills Tax Free Crypto Exchanges? Not Hardly
‘We’ve seen lifelong friends kill each other:’ How a state capital became one of the deadliest US cities
By Peter Nickeas and Priya Krishnakumar , CNN Updated 1408 GMT (2208 HKT) December 28, 2021 Jackson, Mississippi (CNN) Around Thanksgiving, this crisis-plagued state capital saw a series of shootings that pushed the year's homicide total past 130, setting a grim annual record for a city that over the last two years has quietly become one of the country's deadliest. The killings, like so many in another record-setting year of American gun violence , are not the kind that receive national attention. A local business owner was shot outside a barbershop while sitting in his car . A few days later, a man was killed in a shooting that also wounded a 13-year-old boy . A 22-year-old inside a car was sprayed with gunfire at a gas station . A 63-year-old man whose death by gunfire is still largely unexplained . In the state's most populous city, a former Confederate stronghold that would later give way to thriving Black business districts and serve as a hub for the … [Read more...] about ‘We’ve seen lifelong friends kill each other:’ How a state capital became one of the deadliest US cities
World equities rise on bounce in United States, European markets
Representative image Global shares rose on Friday and investor sentiment stabilized after a volatile week of trading, helping to push up stock indexes in the United States and Europe. Global markets, particularly U.S. stocks, have gyrated wildly this week as investors grew anxious about the possibility of a recession. The S&P is nearly 20% down from its all-time high in January and was close to a bear market on Thursday. Investors are anxious about whether U.S. Federal Reserve Chair Jerome Powell can accomplish a "soft landing," where the Fed raises interest rates just enough to reduce elevated inflation without causing the economy to contract. In an interview late on Thursday, Powell said the battle to control inflation would "include some pain," and he repeated his expectation of half-percentage-point interest rate rises at each of the Fed's next two policy meetings. The war in Ukraine has aggravated supply chain disruptions and inflationary pressures already in … [Read more...] about World equities rise on bounce in United States, European markets
Reverse Mortgage Rules by State
In addition to Federal laws regulating reverse mortgage loans, 24 states plus the District of Columbia have their own regulations in the form of laws that govern how these loans are handled within that state. Many state-level regulations mirror those of the Federal government for federally backed home equity conversion mortgages (HECMs) . Others may apply to non-federal reverse mortgage loans such as single-purpose reverse mortgages and proprietary reverse mortgages . In other cases, state law expands on or goes beyond Federal law. Where state-level reverse mortgage rules appear in state law codes varies. Sometimes they are listed as part of banking laws. Other times they appear among real estate or mortgage rules. The state of Texas uniquely codified reverse mortgage law as an amendment to the state constitution in 1997. Key Takeaways State-level laws provide additional guidance regarding reverse mortgage loans and are found in 24 states, plus the District of … [Read more...] about Reverse Mortgage Rules by State
How To Take Advantage Of Tax Season To Tackle Estate Planning
Share to Twitter Share to Linkedin By Renee Fry, Founder and CEO, at Gentreo As Ben Franklin noted, there are two certainties in life—death and taxes. Tax season was just upon us here in the U.S., which many of us are relieved to have just checked off. Preparing for death and emergencies when we need others to make decisions for us is something most of us have not done. A 2021 Gallup poll showed less than 46% of Americans surveyed have a will, a staggering figure given the consequences of not doing estate planning. Whether it is paying thousands of dollars in legal fees to have judges make decisions for your loved ones or witnessing families break up over resulting legal battles, the consequences of not doing estate planning are enormous and costly. According to experts, without estate planning documents, an estate loses anywhere from 3% to 8% of its value to legal costs and fees . Outdated documents can also prove costly as they require court … [Read more...] about How To Take Advantage Of Tax Season To Tackle Estate Planning
DeSantis Wants State Government To Control Disney World’s Special District
Share to Twitter Share to Linkedin Topline The Florida government could assume control of the special district that oversees Walt Disney World, Gov. Ron DeSantis (R) said Monday, after he and state Republicans abruptly voted to wrest control of the district away from Disney and spooked local lawmakers over possibly having to cover the costs. Key Facts DeSantis and the Republican-controlled legislature enacted a law in April dissolving the Reedy Creek Improvement District after Disney opposed HB 1557—known to critics as the “Don’t Say Gay” law—which restricts classroom instruction on sexual orientation and gender identity. Responding to criticism that getting rid of Reedy Creek could burden local county governments and raise residents’ taxes, DeSantis suggested it’s “more likely” that the state would take control to “make sure that we’re able to impose the law and make sure we’re collecting the taxes.” There are a “whole bunch of things” … [Read more...] about DeSantis Wants State Government To Control Disney World’s Special District
Cahya Mata Sarawak 1Q net profit down 7.42% on higher tax expenses
- A + A KUALA LUMPUR (May 18): Cahya Mata Sarawak Bhd (CMS) posted a 7.42% drop in net profit for the first quarter ended March 31, 2022 (1QFY22) to RM72.02 million, from RM77.8 million a year ago, despite an improvement to its quarterly revenue. The group’s filing on Wednesday (May 18) showed that its quarterly revenue had climbed 5.93% to RM214.04 million in the quarter under review versus RM202.06 million in the previous corresponding quarter. The group attributed the lower net profit to higher tax expenses recognised in relation to higher taxable income from its divisions. It noted that its 1QFY21 earnings also included one-off gains from the disposal of Kenanga Investment Bank Bhd (KIBB) shares — amounting to RM28.52 million — and disposal of land and investment properties — amounting to RM16.99 million. Meanwhile, CMS attributed the improved revenue to higher revenue contributions from its cement and road maintenance divisions of 7% and 36% respectively. … [Read more...] about Cahya Mata Sarawak 1Q net profit down 7.42% on higher tax expenses
529 ABLE Accounts: Helping End Forced Poverty For Disabled Individuals
Share to Twitter Share to Linkedin Living with a disability comes with all kinds of challenges, but the financial impact of being unable to work can be absolutely devastating. Imagine not being able to support yourself due to your disability, but also not being able to save money so you can continue qualifying for government aid including Supplemental Security Income (SSI). To qualify for SSI , your countable resources must not be worth more than $2,000 for an individual or $3,000 for a couple. No matter how you cut it, that’s not very much. This situation creates a kind of forced poverty for many individuals with a disability and the family members who care for them. But many experts say that the 529 ABLE Account, which was first introduced in 2014, can help curb this ongoing problem. What Is A 529 ABLE Account? According to the Internal Revenue Service (IRS) , 529 ABLE Accounts were introduced as part of The Achieving a Better Life … [Read more...] about 529 ABLE Accounts: Helping End Forced Poverty For Disabled Individuals