Tag Archives: greenberg traurig

International Tax Survival Guide: Countdown to Common Reporting Obligations for Global Individuals

The due date for filing 2017 U.S. federal income tax returns for individuals who have requested an extension is Oct. 15, 2018. With only one month left until the deadline, we have prepared a countdown of 10 common tax reporting obligations that may be relevant to global individuals with cross-border assets or activities. 10, 9, … Continue Reading

California Locally Assessed Property Tax: 2018 Appeal Filing Deadline Approaching

County Assessors across California believe that the property located in their counties is worth substantially more this year than it was last year. Each Assessor is required to prepare an annual assessment roll consisting of all taxable property in their county. In many counties, roll values increased substantially: San Francisco (↑10.80 percent), San Mateo (↑8.03 … Continue Reading

Limitations for Charitable Deductions and SALT Credits

The Tax Cuts and Jobs Act (TCJA) placed a $10,000 annual limit on the deductibility of state and local taxes (SALT). In response to and attempting to work around that limitation, several states enacted programs that create charitable entities, contributions to which would entitle the donor to a credit reducing their property tax. This would … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for September 2018 – Trending Up Again

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following month … Continue Reading

IRS Disclosure Rules for Some Exempt Organizations Changed

On July 17, 2018, the Treasury Department issued new guidance for certain tax exempt organizations. The guidance pertains to the disclosure of the names and addresses of donors to organizations exempt from federal income taxes under Section 501(c) of the Code, other than organizations exempt from taxes under Section 501(c)(3) (generally charities, religious organizations, and … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for August 2018

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the … Continue Reading

Supreme Court Internet Sales Tax Case Will Require Many Companies to File State Corporate Income Tax Returns – Even If They Are Not Subject to Sales Tax

Although the sales tax collection obligation of online retailers was the focus of last month’s momentous U.S. Supreme Court case South Dakota v. Wayfair, it will also impact state corporate and income tax obligations. Companies may now be exposed to state income tax as a result of the Wayfair case and should examine their activities … Continue Reading

South Dakota v. Wayfair: Supreme Court Holds No Physical Presence Required for Online Retailer to be Required to Collect Sales Tax

On June 21, 2018, the U.S. Supreme Court in South Dakota v. Wayfair, Inc., et al., decided (5-4 although not the usual liberal/conservative split) that an online retailer does not have to maintain a physical presence in a state in order to be required to collect the state’s sales and use tax. This opinion overturns … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for July 2018 – Upward Trend Continues

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for June 2018 – Trending Up

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the … Continue Reading

Imposing a Tax Collection Obligation on Internet Sellers–South Dakota v. Wayfair

This week the U.S. Supreme Court heard oral arguments for South Dakota v. Wayfair, regarding whether physical presence is required within a state for sales and use tax purposes, specifically addressing internet sellers. The case is challenging the Court’s 1992 decision in Quill v. North Dakota, 504 US 298, which upheld a decision from 1967 … Continue Reading

NY Enacts Payroll Tax Law in Response to Federal SALT Deduction Limitation

The Tax Cuts and Jobs Act (TCJA) limited the deduction for state and local taxes (SALT) to $10,000 for federal tax purposes. For those living in states that impose a personal income tax, this limitation may result in an increase in federal tax if their deductions for property taxes and income taxes paid to states … Continue Reading

Token Issuers and Purchasers, Beware: The IRS May Tax Each Time Tokens are Used

Many blockchain companies are using a largely unregulated means of raising funds, commonly known as an initial coin offering (ICO).[1]  An ICO consists of the issuance of a newly generated cryptocurrency (generally referred to as a token) that runs on blockchain technology, in exchange for fiat currency (such as U.S. dollars) or other cryptocurrencies like … Continue Reading

IRS Announces April 2018 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated by the IRS under Section 1274(d) of the Internal … Continue Reading

GT Alert: Estate Planning Under the Tax Cuts and Jobs Act

On Dec. 22, 2017, the Tax Cuts and Jobs Act (the Act) was signed into law. It is the most sweeping federal tax legislation in decades and significantly changes the landscape of individual, corporate, partnership, international, and trust and estate taxation. In general, the changes made by the Act take effect as of Jan. 1, … Continue Reading

IRS Announces it Will End the Offshore Voluntary Disclosure Program Effective September 28, 2018

The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018.  The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to come forward before the September 28, 2018 deadline and become compliant.  Therefore, US taxpayers who have unreported foreign assets and income have a limited amount … Continue Reading

Tax Cuts and Jobs Act Disallows Deductions for Many Payments Due to Violation of Civil and Criminal Law

A provision in the new tax law greatly expands the scope of the disallowance of deductions for fines and penalties paid to government agencies. The new law disallows a tax deduction for any payment made to a government entity where the payment was made in relation to a violation of law or the investigation of … Continue Reading

Greenberg Traurig Will Sponsor and Host Washington Women’s Leadership Initiative (WWLI) Event

On March 7, 2018, Greenberg Traurig’s Northern Virginia office will host the WWLI event featuring Dr. Sachiko Kuno, the founder and visionary creative behind Halcyon House.  Dr. Kuno will share her journey from entrepreneur to philanthropist and the inspiration behind Halcyon House, an environment for artistic and social innovators to transform their inspiration into impact … Continue Reading
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