What is business succession planning, and why is this an important and essential component of forming any new entity or protecting an existing business interest? Business succession planning protects everything you’re working to build by ensuring sound corporate management and decision-making continues if you are injured, disabled, or after your...
Why is a PFIC a Potentially Punitive Tax Consequence
What is a Passive Foreign Investment Company or PFIC, and why is a PFIC a potentially punitive tax consequence? Why is it important for any U.S. expatriate or U.S. taxpayer living or investing overseas to understand the concept of a PFIC and the implications these investments have on income tax...
A Transactional Approach to Business and Investment Planning
Why should you consider a transactional approach to business and investment planning? What is the best strategy to protect your assets while structuring gains and losses to minimize tax exposure? Key Takeaways Regarding a Transactional Approach to Business and Investment Planning: Most savvy business and investment professionals approach business and...
IRS Continues to Tighten Focus on U.S. Cryptocurrency Investors
2025 has brought substantial new challenges as the IRS continues to tighten its focus on U.S. cryptocurrency investors. Cryptocurrency brokerages are required to report gross proceeds for each digital asset transaction they manage on IRS Form 1099-DA. This requirement applies to all digital currency transactions on or after January 1st...
How Tariffs Have Impacted General Business and Tax Strategy
As the Supreme Court of the United States (SCOTUS) considers the legality of Trump tariffs under the IEEPA, including V.O.S. Selections, Inc. v. United States and Learning Resources, Inc. v. Donald Trump, it is important to consider how tariffs have impacted general business and tax strategy, as well as the path forward...
Is the Burden of Proof on the IRS During an Audit?
Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS. Key Takeaways on Is the Burden of Proof on...
What You Need to Know About the IRS Math and Taxpayer Help Act
What do you need to know about the IRS Math and Taxpayer Help Act? What is the status of the reforms contained within the provisions of H.R. 998? Important Takeaways About the IRS Math and Taxpayer Help Act: The U.S. House of Representatives passed H.R. 998, The IRS Math and...
U.S. Taxpayers with Offshore Investments Should Be Wary of PFICs
U.S. taxpayers with offshore investments should be wary of PFICs (Passive Foreign Investment Company). Many foreign nationals live and work in the United States. For those who invest in offshore companies that generate income in a passive nature (i.e. rents, royalties, interest, income from commodities or derivative trading) are permanent...
Managing an IRS Correspondence Audit
One of the new realities for U.S. taxpayers includes the responsibility for managing an IRS correspondence audit. What should you do if you are contacted regarding any form of IRS audit? Did you know the present majority of IRS audits are known as "correspondence audits?" What is a correspondence audit,...