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November 2016 Archives

What triggers a prison sentence in offshore prosecutions?

Willfulness is usually required to support criminal charges. Assigning signature authority to someone else to conceal account ownership could show willful conduct. Filing a document, such as a Foreign Bank and Financial Accounts/FinCEN Report 114 (FBAR) with false information is another.

Tax penalties: Does the IRS need clearer standards for using them?

The IRS's budget has been going down, not up. These cuts have made the agency less able to play its accustomed customer-service role in helping taxpayers comply with the U.S. tax code.To be sure, the IRS also has its enforcement side, with penalties, audits, investigations and collection actions.

New rules on taxation of intercompany debt

Federal regulation of businesses is poised to change with the new administration, with important implications for tax compliance.President-elect Trump has promised to roll back business regulation across the board. And with his surprising victory this week, he is in a position to put that promise into practice.But it doesn't necessarily take a change of administration for there to be changes in tax rules to benefit businesses. In this post, we will inform you about one such change. It concerns "cash pooling," a technique that raises concern for regulators about so-called "earnings stripping."

Proposed estate tax rules could disparately impact franchisees

The IRS has reportedly received more than 8,000 public comments regarding proposed changes to how the agency determines valuation discounts under Section 2704 of the U.S. Tax Code. This provision, contained in Reg-163113-02 of the agency's regulations, deal with discounts allowed for valuation of business holdings and assets for purposes of calculating estate tax.

Election angst leads many to consider moving abroad

According to some sources, Google searches for "emigrating to Canada," "moving abroad" and "leaving the U.S." (among others) spiked the night of the first election debate between Hillary Clinton and Donald Trump. Say what you will about either candidate, the truth remains that this election cycle has been a tumultuous one that has inspired deep feelings in supporters on both sides. These feelings have even inspired many to consider a radical solution if their candidate doesn't come out on top: moving out of the country.

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