The Ups and Downs of the Program for Voluntarily Reclassifying Your Workers
Whether a worker is properly classified as an employee or as an independent contractor depends upon the facts and circumstances. Generally, the determination is made under common law tests considering the right to control and direct the individual performing services. However, in some factual situations, the determination of the proper worker classification status may not […]
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Costa Rica Expats May Soon Experience the Benefits of Residency-Based Taxation
Glen E. Frost, Esq., CPA, CFP®; Associate Tax Counsel, American Citizens Abroad For many years, the persistent call for change in the taxation of American corporations and individuals abroad has gone unanswered. However, the current administration’s actions, suggest the very real possibility of new tax rules, sooner rather than later. Indeed, assuming no major legislative […]
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Comparison of the House and Senates Tax Cuts and Jobs Act
The below comparison outlines the “Tax Cuts and Jobs Act” passed by the House of Representatives on November 16 and the Senate on December 2. Since the two plans differ, they will now be sent to a conference committee where negotiators from both chambers will create a unified bill. After, both parties must approve the […]
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Launching a Business? It’s Time to Meet With a Tax Attorney
A tax attorney is uniquely skilled to help individuals with various tax matters, such as resolving tax controversies with the IRS and creating tax plans to minimize liability; however, a tax attorney can also help you launch your business. Here’s how. Starting your own company is an incredible experience. Maybe you’ve been dreaming of launching […]
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Maryland Emergency Regulations and Tax Alert in Wake of Wayfair
Rebecca Sheppard, Esq., Partner On August 29, 2018, in response to South Dakota v. Wayfair,the Maryland General Assembly’s Joint Committee on Administrative, Executive, and Legislative Review (AELR) approved the Comptroller of Maryland’s emergency regulations imposing economic nexus standards to require remote vendors lacking Maryland physical presence to collect Maryland sales tax on in-state sales. Wayfair […]
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QBI Guidance Issued; Safe Harbor Provided for Real Estate Enterprises
Eli S. Noff, Esq. CPA, Partner As we detailed in Section 199A: New 20% Pass-Through Deduction1, the Tax Cuts and Jobs Act of 2017 created new Internal Revenue Code §199A-providing a significant tax break to flow-through entities and structures. Subject to certain limitations, many eligible taxpayers (excluding C corporations) may deduct up to 20% of […]
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Form 4340 is Sufficient Corroborating Evidence Proving Issuance of Notice of Deficiency
Eli S. Noff, Esq. CPA, Partner On January 28, 2018, the court in U.S. v. Meyer,1considered a challenge to the proper mailing of Notices of Deficiency for two tax years and found Form 4340 sufficient as corroborating evidence for both years. Background A deficiency assessment results from the Internal Revenue Service’s (IRS) finding that a […]
HoweyCoin—Too Good to be True
“If you’ve ever been tempted to buy into a hot investment opportunity linked with luxury travel, the Securities and Exchange Commission has a deal for you.” Sound too good to be true? It is. This announcement was made in the May 16, 2018 U.S. Securities and Exchange Commission (SEC) press release which was issued to […]
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Audit of the Offshore Voluntary Disclosure Program
The Treasury Inspector General for Tax Administration (“TIGTA”) completed an audit of the Offshore Voluntary Disclosure Program (“OVDP”). US citizens are taxed on their worldwide income and must report bank accounts when their aggregate balance exceeds $10,000. The OVDP and other similar programs allow taxpayers a mechanism to come forward and get into compliance with […]
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Celebrities’ Initial Coin Offering Endorsements Under SEC Scrutiny
Cryptocurrency start-up firms sometimes attempt to raise funding for an original cryptocurrency venture through Initial Coin Offerings (ICOs). Typically, the firm presents a whitepaper plan detailing the: (1) project requiring funding, (2) amount of funding needed, (3) amount of cryptocurrency that investors will retain, (4) specific currency accepted, and (5) timeline for the ICO campaign. […]
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