Tax

Summary:California has overcharged multistate businesses on income tax bills for years, the California Court of Appeal, Fourth District, held on July 24, 2012. Multistate businesses that have paid California income taxes between tax years 2007 and today should contact Royse Law Firm, PC, to...

In June 2012 the IRS issued REG-134042-07, containing proposed regulations that would clarify the basis of indebtedness of S corporations to their shareholders.The proposed regulations would allow some taxpayers to take greater deductions on the losses of debt-financed S corporations. Background: When a shareholder loans money to...

July 5, 2012The Foreign Account Tax Compliance Act (FATCA), enacted as part of 2010 Hiring Incentives to Restore Employment (HIRE) Act, is a reporting regime designed to ensure US citizens and residents pay appropriate US taxes on specified foreign financial assets.FATCA focuses on foreign financial...

Internal Revenue Code (I.R.C.) Section 7874 regulates corporate and partnership inversions. An “inversion” occurs when an entity elevates a subsidiary in a low-tax jurisdiction (e.g., Bermuda) to a parent position, inverting the previous affiliation and becoming a subsidiary of the foreign-headquartered entity.By relocating one’s headquarters...

All United States persons, including citizens, green card holders, and individuals considered US residents based on the duration of their stay in the United States, are required to annually report their ownership of, or signature authority over, foreign bank accounts.The form for such reporting is...

In 2010, the U.S. government enacted the Foreign Account Tax Compliance Act (FATCA), containing provisions that would require, starting in 2013, foreign financial institutions (FFIs) to provide to the IRS the personal information of any United States persons holding accounts at that FFI.See https://rroyselaw.com/blog1/2012/01/12/third-offshore-voluntary-disclosure-program-announced-by-irs/.The...

Under Section 6045B of the Internal Revenue Code of 1986, as amended (the "Code") many corporations are required to file a new return (Form 8937) with the IRS in connection with non-dividend distributions and other corporate actions affecting stock basis.More specifically, starting in 2011, the...

In 2009 and 2011 the Internal Revenue Service (IRS) created two temporary initiatives to allow U.S. taxpayers with unreported income relating to undisclosed foreign bank or financial accounts to make a voluntary disclosure to get current with their taxes and information filing obligations.On Monday, January...

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