By Gina Gatchell, Director In 2010 I received a call from a very upset US citizen about the enactment of the Foreign Account Tax Compliance Act. She sent me the article she had just read, which set out the future of information reporting by institutions outside the...
New Zealand has both extinct and dormant volcanoes and is overdue for an eruption. By Gina Gatchell, Director With enough rumblings to cause a volcanic eruption, the capital gains tax debate is currently raging in New Zealand. The bonfire was ignited after the Tax...
Are you getting the classification of your trust correct for US tax purposes? In 2018 the Internal Revenue Service started a campaign targeting foreign trusts’ failure to comply with the filing requirements of US owners[1] of foreign trusts, including ownership, and...
The Tax Court case of Virginia-based taxpayers Toso & Salman tested several US tax principles which affect all US citizens and residents[1]. Those principles include the statute of limitations, the definition of ‘gross income’, and the ability to offset...
It is not hard to deduce that the effects of the partial US government shutdown, on the Internal Revenue Service (IRS) are acute. Predictions vary as to how long it will take for the agency to rehabilitate; this is expected to be at least a year. The American...
Section 988 of the Internal Revenue Code Treatment of Certain Foreign Currency Transactions taxes certain transactions defined as ‘Section 988 transactions’. The general rule is that the disposition of any non-functional currency will be treated as a section 988...
