A Guide to International Tax Planning
While operating in multiple jurisdictions, the company must obey all the laws including tax laws of those countries. This means if the company operates in more than one country, it must pay the appropriate taxes from these countries. For companies, the tax issue is a financial headache and can be real legal and international tax […]
United States v. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context
On April 3, 2018, in United States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government’s suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of proof is preponderance of evidence, and (2) proof of reckless conduct […]
I.R.C. §280E: A Buzzkill For Those Who Keep Poor Records
The recent Tax Court’s Alterman v. Commissioner[1] decision is a lesson in Accounting 101 for Cannabisseurs. Well, technically it’s a valuable lesson about record-keeping to all taxpayers who are subject to Internal Revenue Code (I.R.C.) §280E-but with the currently high audit rates for the marijuana industry, it’s particularly significant for taxpayers currently in that business. Before learning […]
Virtual and Economic Contacts Establish Nexus for Sales Tax
On June 21, 2018, the Supreme Court delivered its highly anticipated decision in South Dakota v. Wayfair, Inc., et al.[1] The 5-4 decision discards the antiquated “physical presence rule” – a rule which has allowed retailers lacking a physical presence in a state to avoid any obligation to collect and remit sales taxes. Significantly, the Court overruled […]
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 […]
Release or Withdrawal of Federal Tax Lien: Which is Better?
When you fail to pay the taxes you owe to the government after the Internal Revenue Service sends you a bill with an explanation for how much you owe, the tax collection agency could place a lien against your property. This lien essentially protects the government’s interest in your property, which could include personal property, […]