Tax

US State-to-State Business Travel Compliance and Risks

While organisations often overlook tax-compliance requirements related to business travel, the days of simply traveling to and working in a different state or country for business without a thought to tax liabilities are coming to an end. Looking for additional tax revenue, US state taxing authorities are becoming stricter and more vigilant in monitoring business travel. Extensive time spent on business travel in a country outside the US, or even a different state within the US, could create a PE exposure for the employing entity.

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US State-to-State Business Travel Compliance and Risks2019-10-28T12:48:00-05:00
Tax| Oct 15, 2019

How the Change in US Sales Tax Rules has Impacted International Sellers

On 21 June 2018, the US Supreme Court passed a landmark decision that transformed the landscape of sales tax in the US. The South Dakota vs Wayfair decision effectively permitted states to create new rules for sales ­tax collection requirements based on the dollar or transactions amount of sales - otherwise known as economic nexus. Previously, companies were only required to collect sales tax based on a physical presence test.

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How the Change in US Sales Tax Rules has Impacted International Sellers2019-10-15T14:41:12-05:00

Operating in a Complex World: The Argument for Not-for-Profits to Change Everything

Originally published by Long Island Business News Profit. When we hear the word profit, we think of Wall Street, shareholders, stocks, global conglomerates, and billionaire CEOs; we don’t conjure up the image of a not-for-profit organization helping provide services to the community.

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Operating in a Complex World: The Argument for Not-for-Profits to Change Everything2019-09-17T10:48:57-05:00
Tax| Aug 19, 2019

New Opportunity Zone Regulations: What They Are and What They Clarify

Tax| Aug 19, 2019

In December of 2017, the Tax Cuts and Jobs Act outlined a new program called “Opportunity Zones” (OZs) that offered tax breaks for investing in underdeveloped/distressed communities via Qualified Opportunity Funds (QOFs). In October 2018, substantially more detail on the OZs was provided, and in April 2019, the IRS and Treasury Department issued a 169-page document that detailed regulations governing OZs. According to the IRS, a QOF is set up either as a partnership or corporation (LLCs qualify also) for investing in an eligible property located in one of the OZs.

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New Opportunity Zone Regulations: What They Are and What They Clarify2019-10-31T10:36:07-05:00

Selling Across the Pond: What UK Residents Need to Know When Selling US Property

For UK citizens selling a property in the USA, completing the sale is only your first hurdle. Your next challenge is tax - both in the UK and the USA - neither set of rules being straightforward. Taking UK tax first, if you are resident and domiciled in the UK, you will have capital gains tax (CGT) to pay on any gain achieved on the sale of US property.

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Selling Across the Pond: What UK Residents Need to Know When Selling US Property2019-10-31T10:36:28-05:00
Tax
|By Karen H. Kerby & Robert Crowley
| Jun 20, 2019

Fund Support

Audit & Accounting
|By Karen H. Kerby & Robert Crowley
| Jun 20, 2019

How can Prager Metis help new managers when they are in the pre-launch stage? We can help in a number of ways. We would work closely with their attorneys to determine what the fund structure should look like.

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Fund Support2019-10-31T10:36:42-05:00

US Tax Compliance for Foreign Trusts: A Primer

A threshold question in determining how a trust will be taxed in the US is whether the trust is foreign or domestic. The default rule is that a trust is foreign, unless the trust fails both the “Court Test” and the “Control Test.” The Court Test is met if a US court is able to exercise primary supervision over the administration of the trust. The “Control Test” is satisfied if one or more US persons have the authority to control all substantial decisions of the trust.

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US Tax Compliance for Foreign Trusts: A Primer2019-10-31T10:34:14-05:00

Tax Planning Under the New US Tax Reform

The US Tax Cuts and Jobs Act, passed on 17 December 2017, has dramatically changed the analysis and available strategies for structuring cross-border operations. Meaning, to realise tax optimisation, business owners must be aware of those changes. For example, in addition to a decreased corporate rate from 35% to 21%, and the full expensing of plant and equipment acquisitions, there is a now a reduced effective rate of 13.125% for domestic companies’ income from selling products or services to foreign customers directly or through related parties.

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Tax Planning Under the New US Tax Reform2019-10-31T10:34:20-05:00
Tax| Apr 18, 2019

Practical Considerations Regarding Section 199A of the New US Tax Law

Tax| Apr 18, 2019

The Tax Cuts and Jobs Act passed by the US Congress on 17 December 2017, includes Section 199A, a provision that can afford pass-through businesses a 20% deduction of: Qualified business income (QBI) from a domestic qualified trade or business (QTOB) operated as a sole proprietorship, partnership, S corporation, trust or estate; Combined qualified real estate investment trust (REIT) dividends and qualified publicly traded partnership (PTP) income.

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Practical Considerations Regarding Section 199A of the New US Tax Law2019-10-31T10:34:27-05:00