Tax notes

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

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

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

Share to Twitter Share to Linkedin As we enter the middle of Tax Season 2021, I'm hearing a lot of people asking the following questions about their mortgage interest, "Can I still deduct my home equity line of credit ? Should I refinance to make it tax-deductible again? How do I know if I can deduct the home equity line of credit (HELOC) interest?" Below, we will answer your questions and more. Home Equity Lines of Credit (HELOC) Basics This mortgage tax break continues to confuse many homeowners when filing taxes. Adding to the confusion are the mortgage tax deduction changes in the Tax Cuts and Jobs Act (TCJA) of 2017 . I have been vocal over the years about how bad these changes are for most of my home-owning clients. For many homeowners, there are quite a few cases where the interest on a HELOC can be deductible, but there are also many times HELOC interest will not be tax-deductible. For those with valuable real estate holdings, just a … [Read more...] about Can I Still Get A Tax Deduction For My HELOC Mortgage?

Share to Twitter Share to Linkedin Tax audits are down. By a lot. Internal Revenue Service audit rates of individual taxpayers’ returns have dropped for all income levels from tax years 2010 to 2019, according to a new Government Accountability Office report. On average, individual tax returns were audited over three times more often for tax year 2010 (0.9 percent) than for tax year 2019 (0.25 percent). Audit rates for taxpayers with incomes between $200,000 and $500,000 saw the biggest drop (a 92% drop), from 2.3% in 2010 to 0.2% in 2019. For the highest income taxpayers, those with income of $10 million or more, the audit rate dropped from 21.2% in 2019 to just 3.9% in 2019 (an 81% drop). Here’s a look at how much audit rates are declining: Table 3 in the report, Trends of IRS Audit Rates and Results for Individual Taxpayers by Income , has more detailed numbers. The drop in audits is good news for tax cheats and bad news for the rest of … [Read more...] about IRS Tax Return Audit Rates Plummet

- A + A (May 14): Macau is considering revising a casino bill, including a potential cut in some of the world’s heftiest gaming taxes, as the gambling hub faces plunging revenue amid China’s Covid-19 lockdowns. Share prices of the city’s licensed casino operators soared in the US on Friday (May 13) after Macau media first reported the proposed revisions. Las Vegas Sands Corp and Melco Resorts & Entertainment Ltd each rose 15%, while Wynn Resorts Ltd jumped 13%. The Chinese enclave is willing to consider a tax cut of as much as 5% on casinos’ gaming revenue if they are able to bring in players from outside of China, local media including GGR Asia reported. The reports cited Chan Chak Mo, the president of a committee of the Macau legislature that is currently scrutinising a draft bill to amend the city’s gaming law. The city currently taxes casino operators about 40% of gaming revenue. The government believes the city had been relying on mainland China too much … [Read more...] about Macau mulls casino tax cut as gaming revenue plummets

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

- 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

So your home loan has finally been disbursed and you can now proudly call yourself a homeowner. This is indeed one of the most cherished and expensive investments you’ll make in your life. But have you ever thought of the possibility of something happening to you before you pay your full home loan? Your liabilities will be handed over to your family members, leaving them under financial stress. While there are various things to consider before investing in a house, we often neglect important add-ons such as an insurance policy that covers your home loan repayments. There are two ways to prevent your family from the burden of such liabilities – home loan insurance or a term insurance policy . Both policies provide cover against financial stress. The main difference between them is that a home loan covers the property, while a term policy covers a person’s life. Let’s dig deeper to understand the differences. Premium charges Close Depending on needs and … [Read more...] about Securing a home loan liability: Home loan insurance or term policy?

Share to Twitter Share to Linkedin The Government Accountability Office (GAO) was asked to report on trends in IRS audit rates, audit results, and resources used for audits across individual taxpayer income levels. Their report, issued this week, analyzed audit rates and results and IRS resources used by taxpayer income for the most recent years data was available. According to the report, “In recent years, IRS has examined, or audited, a decreasing proportion of individual tax returns. This trend has raised concerns about the potential for declining taxpayer compliance, as well as whether IRS is equitably selecting taxpayers for audit, as audit rates for higher-income taxpayers have decreased more than audit rates for lower-income taxpayers.” On May 18, 2022 IRS Chief Taxpayer Experience Officer, Ken Corbin, and the GAO Director of Strategic Issues, James McTigue, appeared before the House Ways and Means Oversight Subcommittee (Bill Pascrell, D-NJ, chair) … [Read more...] about GAO Report Highlights Fairness Issues In IRS Audit Rates