The IWTA International Tax Journal
Breaking news, expert advice and opinion on global tax laws and foreign investment strategies.
Tax Cliffs and a Second Trump Presidency
The Tax Cuts and Jobs Act of 2017 introduced significant tax cuts during President Donald Trump’s first term. However, many provisions are set to expire at the end of 2025, which could lead to a “tax cliff” for individuals, families and businesses.
Inernational Tax
Beyond Borders: Implications of Recent Court Cases on Foreign Tax Issues
Foreign trusts, foreign ownership. The rules governing the legal structure of trusts and their associated obligations are complex, and some of these rules aren’t fully defined in the tax law…
International Tax
Navigating the Global Tax Landscape in 2024 – Third Quarter Roundup
It’s been a busy year for global tax issues, between the Global Minimum Tax, worldwide calls for a wealth tax, and significant judicial decisions in the United States…
GILTI Tax and Controlled Foreign Corporations
GILTI tax was enacted under the TCJA (new IRC 951A). IWTA Founder Jack Brister explains…
Tax Cliffs and a Second Trump Presidency
The Tax Cuts and Jobs Act of 2017 introduced significant tax cuts during President Donald Trump’s first term. However, many provisions are set to expire at the end of 2025, which could lead to a “tax cliff” for individuals, families and businesses.
Beyond Borders: Implications of Recent Court Cases on Foreign Tax Issues
Foreign trusts, foreign ownership. The rules governing the legal structure of trusts and their associated obligations are complex, and some of these rules aren’t fully defined in the tax law…
Navigating the Global Tax Landscape in 2024 – Third Quarter Roundup
It’s been a busy year for global tax issues, between the Global Minimum Tax, worldwide calls for a wealth tax, and significant judicial decisions in the United States…
High-Net-Worth Individuals Look to Expand Their Investments
High-net-worth and ultra-high-net-worth individuals are increasingly going outside their primary wealth management relationships to invest in alternative investments, cryptocurrencies, and ESG, according to a survey by PWC.
The Impact of the Global Minimum Tax on Corporate Flows
Is this the end of shifting profits from high-tax to low-tax jurisdictions?
The landscape of international taxation is undergoing a seismic shift with the implementation of the Organization for Economic Co-operation and Development’s (OECD) Global Minimum Tax (GMT).
Redefining the 16th Amendment: The Impact of the Mandatory Repatriation Tax on Ultra High Net Worth Clients
How has a relatively minor tax bill — $14,729 to be exact — turned into one of the most important tax cases for the United States? The matter at hand is whether the United States federal government can tax unrealized gains as income in Moore v. United States (Docket 22–800)…
IRS: Partial Penalty Relief Still Available for 2019 and 2020 Returns, But it Depends…
Amidst the upheaval of the COVID-19 pandemic, some U.S. taxpayers were unable to file their 2019 or 2020 income tax returns within the IRS’ filing deadlines The Internal Revenue Service, in a show of understanding, fully waived penalties for individual taxpayers and businesses who filed certain late returns by September 30, 2022.
IRS New JSEIT Unit Will Use Crowdsourcing, Cooperative Intra-Agency Intelligence and Media Alerts to Quash Emerging Tax Fraud Schemes
Announced in June, the Joint Strategic Emerging Issues Team, or JSEIT, combines expertise from units across the agency, including Criminal Investigation, Tax Exempt/Government Entities, Large Business & International, and Small Business/ Self Employed.
Jack Brister Featured in Live Event: Estate Planning and Investment Strategies for Multi-Nationals on Oct. 25, 2022
Complex Tax and Non-Tax Issues. Trust and estate planning and investment strategies for multinationals is a complex topic about which International Wealth Tax Advisors founder Jack Brister has encyclopedic knowledge.
International Tax Roundup: Third Quarter 2022
2022 has been an unpredictable year amidst soaring inflation and geopolitical unrest. In the tax realm, governments have been trying to hedge against this uncertainty by shoring up their budgets and addressing inconsistent tax enforcement.
What Are Three Essential Tax Laws Foreign Owners of U.S. Real Estate Need to Know?
While U.S. citizens and persons who are deemed to be domiciled can enjoy an estate tax exemption in 2022 of $12,060,000, that figure does not apply to nonresident aliens. The exemption amount for a nonresident alien decedent is actually only $60,000, and any amount that exceeds that figure is subject to estate tax that ranges anywhere from 26% – 40% . The estate tax exemption applies to all assets, not just real estate. Real estate property falls under the blanket estate tax exemption if the property is an asset in a decedent’s estate.
TIGTA Highlights the IRS’ FATCA Enforcement Woes
In the first 12 years of the U.S. Foreign Account Tax Compliance Act, the IRS has spent nearly $600 million on enforcement but has only managed to collect $14 million in penalties in return. This poor performance indicates that the agency strongly needs to revise its enforcement strategy according to a recent audit report by the Treasury Inspector General for Tax Administration.
The Cost of Non-Compliance With IRS Form 926
IRS Form 926 is the form U.S. citizens and entities including estates and trusts must file to report certain exchanges or transfers of property to a foreign corporation. This would include transfers of cash over $100,000 to a foreign corporation, or situations in which the transfer of cash resulted in owning more than 10% of the foreign corporation’s stock. This reporting requirement applies to outbound transfers of both tangible and intangible property
Frozen: How the Revocation of the U.S. – Russia Tax Treaty Puts Global Trade on Thin Ice
This blog post is an update to IWTA founder Jack Brister’s article published in JD Supra on March 18, 2022, entitled, “Frozen: How the Revocation of the U.S. – Russia Tax Treaty Puts Global Trade on Thin Ice.” The Biden administration is poised to fully block Russia’s ability to pay U.S. bondholders. The Treasury Department told multiple news outlets that it had suspended its tax information exchanges with Russia. Read more…
International Tax in 2022: The Year of Disclosure and Investment
For taxing authorities around the world, monitoring taxpayer disclosures and transparency will be a top line item in 2022, meaning taxpayers — especially high-net-worth individuals and corporate entities — should expect more scrutiny into their affairs. Governments are in a unique position as they navigate multiple demands and pressures.
Three Key Tax Implications of the Biden Administration’s New Infrastructure Bill
The long-awaited infrastructure proposal was approved by Congress late last week and has been signed into law by President Joe Biden. As part of the President’s mission to “build back better,” the proposal is a considerable investment in the country’s infrastructure.
And while not as large as once envisioned — originally, it was $3.5 trillion — it is still a substantial amount at $1.2 trillion. Funding for the Infrastructure Bill will come from a few sources.
International tax expert Jack Brister comments on some of the tax changes that will impact businesses and investors.
It Happened in South Dakota
The Pandora Papers, a recent reveal of pervasive cross-border financial crime and elaborately-crafted tax dodging structures, as reported by a global network of investigative journalists, has
already shaken up governments and elections, upended tax authorities and initiated criminal investigations… Perhaps the most intriguing revelation of all from a stateside perspective was the emergence of South Dakota as a preferred tax haven of the rich and famous.
International Tax Guru Jack Brister, founder of International Wealth Tax Advisors, to Appear as Anchor Panelist in Upcoming Webinar on Foreign Trust Tax Reporting
Jack Brister Founder, International Wealth Tax Advisors Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of...
Third Quarter 2021 U.S. Economic Outlook: Vaxed, Taxed, and Roaring Back
It’s been a year and a half since the onset of COVID-19, and there’s encouraging news for clients. The U.S. economy is bouncing back to life thanks in part to government aid and relatively high vaccination rates. The national economy grew at a seasonally adjusted, 6.5% annual rate in the second quarter, a sign that the nation has achieved a sustained recovery from the pandemic-induced recession. In fact, the economy has now surpassed its pre-pandemic levels.
IRS Introduces Tax Relief Measures for Those Impacted by Covid-19
IWTA Breaking Tax News: IRS Introduces Tax Relief Measures for Those Impacted by Covid-19.
On November 2, 2020 the Internal Revenue Service announced changes designed to de-stress taxpayers filing late 2019 returns, and those that have fallen behind on previously-negotiated installment agreements or otherwise struggling to pay balances owed.
In short, any taxpayer struggling financially due to the pandemic can take comfort in and advantage of the second phase of tax relief — what the IRS calls its “People First” initiative. This applies to small business owners too, who have been hurt badly by the pandemic-induced economic slowdown.
In 2020 Cryptocurrency is No Longer a “Bit” Player
It is evident that the Covid economy has only intensified the thirst of investors, entrepreneurs and increasingly, average citizens, for an economic model that more seamlessly marries with life-in-the-digital-lane. This article updats the shifting landscape of cryptocurrency, banking and finance and taxes. The future is here and traditional banking must ride the cryptocurrency blockchain or go the way of the abacus.
Are You FIRPTA Compliant? IRS Targets Foreign Holders of U.S. Real Estate
The U.S. Congress designed the Foreign Investment in Real Property Tax Act (FIRPTA) to collect tax on the sale of a U.S. property by a foreign person or business entity in order to ensure that foreign persons and entities paid tax on their U.S. source (situated) income (i.e., extract a type of capital gains tax that would normally not apply). Looking to boost tax revenues in a tough year of the Covid-19 pandemic, on On October 5th and Sept. 14. 2020, the IRS Large Business & International Division (LB&I) issued notices regarding their resumption of a FIRPTA enforcement campaign.
IRS Cuts FDII and GILTI Some Slack
Last month, on July 9, to be exact, the U.S. Treasury Department and the IRS officially rolled out final regulations under IRS tax code Section 250, providing updated guidance on the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).
Finally- All the Most Frequently Asked Questions About Foreign Trusts in One Place!
This blog post introduces International wealth tax advisors’ new FAQ page on Foreign Trusts on the International Welath Tax Asvisors’ website. The page includes a yes/no quiz which calculates which type (if any) foreign trust you are dealing with. If you need foreign trust reporting, management and tax filing help, know that International Wealth Tax Advisors can be your trusted resource!
Breaking Covid-19 Tax News Update: IRS’ “Substantial Presence 60-Day Covid-19 Waiver is Set to Expire
It looks like the IRS is ending their tax grace period, the 60-day “Covid-19 Emergency Period” for eligible non-resident alien individuals. In U.S. Treasury Department terms, IRS Rev. Proc. 2020-20 and Rev Proc 2020-27 are coming to an end.
The IRS released relief measures (Rev. Proc 2020-20, Rev. Proc. 2020-27) in April 2020. In brief, the measures allowed nonresident individuals, foreign corporations, and partnerships to choose a 60-day period between Feb. 1 and April 1 in which the IRS would not consider their U.S. activity to trigger a tax liability. The agency updated its relief information earlier in June 2020.
Breaking Tax News Week of June 8, 2020
Jack Brister Founder, International Wealth Tax Advisors Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of...
A Taxing Pandemic: Covid-19 and Cross-Border Tax Issues
As they say in the news business, Covid-19 is a “developing story,” and the adjustments being made by the U.S. Treasury department to address the unique tax issues arising as a result of the pandemic are historic. IWTA Founder and Managing Member Jack Brister comments on three pressing cross-border tax issues arising from the coronavirus global pandemic, with links to guidelines issued by the IRS.
Breaking News Update: U.S. Department of Treasury Offers Tax Relief to NRAs Remaining in USA During Covid-19 Pandemic
Breaking Tax News as of April 21, 2020: The following is an addendum to our original blog post of April 20, 2020 entitled:
“The Perfect Storm of Timing, Tragedy and Tax Law: NRAs and Covid-19”
Recognizing the unusual circumstances non-resident aliens have faced while sick, trapped or morally obligated to remain in the USA during the Covid-19 pandemic, the U.S. Department of Treasury has relaxed rules regarding what is commonly referred to as “the substantial presence test.”
Top Tips for International Tax Clients During the Covid-19 Crisis
At International Wealth Tax Advisors, we’re suggesting cross-border tax clients, both U.S. citizens and foreign nationals, consider the following tips to help mitigate any unexpected tax and financial consequences as a result of the Covid-19 pandemic.
The Perfect Storm of Timing, Tragedy and Tax Law: NRAs and Covid-19
The outbreak of COVID-19 (the coronavirus) has significantly disrupted and impacted the world. The global nature and dramatic lock down /stay at home orders undertaken by governments around the world have left many individuals and families dislocated. Among the victims: non-United States persons (NRAs) stricken with the disease while visiting the U.S. and unable or unwilling to return to their country of residence.