Tax

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.

Read More

US Tax Compliance for Foreign Trusts: A Primer2019-10-31T10:34:14-04:00
Tax | Apr 18, 2019

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.

Read More

Tax Planning Under the New US Tax Reform2019-10-31T10:34:20-04:00
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.

Read More

Practical Considerations Regarding Section 199A of the New US Tax Law2019-12-18T10:43:21-05:00
Tax | Feb 11, 2019

The Taxation of Income from Cryptocurrencies in Various Jurisdictions — USA

Tax | Feb 11, 2019

Recently, we have seen a growth in the sale or exchange of cryptocurrency, or the use of cryptocurrency to pay for goods or services. Unfortunately, guidance from the Internal Revenue Service (IRS) pertaining to related US income tax issues has not kept pace with the proliferation of cryptocurrency trading. This article highlights fundamental income US tax compliance issues for investors dealing or transacting in cryptocurrency.

Read More

The Taxation of Income from Cryptocurrencies in Various Jurisdictions — USA2019-09-24T14:41:30-04:00
Tax | Feb 04, 2019

IRS Clarifies 199A Section of Tax Law, Provides Safe Harbor and a 20% Deduction To Rental Real Estate Enterprises

Tax | Feb 04, 2019

If you own rental real estate, the fact that the IRS just issued Notice 2019-7, which clarifies Section 199A of the Tax Cuts and Jobs Act of 2017 could work to your benefit. The clarification will help in determining whether a rental real estate enterprise is a trade or business for the purposes of section 199A. From the outset, Section 199A sought to extend benefits of the Tax Cuts and Jobs Act to small businesses.

Read More

IRS Clarifies 199A Section of Tax Law, Provides Safe Harbor and a 20% Deduction To Rental Real Estate Enterprises2020-01-03T11:18:50-05:00

E. Martin Davidoff, National Managing Partner of the Tax Controversy Practice Quoted in Accounting Today

E. Martin Davidoff, National Managing Partner of the Tax Controversy Practice at Prager Metis, was quoted in a recent Accounting Today article titled: “Like ‘1986 on steroids.’” Click here to read the full.

Read More

E. Martin Davidoff, National Managing Partner of the Tax Controversy Practice Quoted in Accounting Today2019-10-22T14:32:10-04:00
Tax | Dec 13, 2018

Key Tax Cuts and Acts Affecting Asset Managers

Tax | Dec 13, 2018

With the K-1 season right around the corner, now is the perfect time to highlight a few key concepts that will directly affect fund managers from the Tax Cuts and Jobs Act (“TCJA") that was enacted on December 22, 2017. Limits on Deductibility of Business Losses TCJA imposes a new limit on the deductibility of business losses incurred by taxpayers other than corporations.

Read More

Key Tax Cuts and Acts Affecting Asset Managers2020-01-03T11:27:05-05:00
Tax | Dec 06, 2018

Opportunity Zones: A Win/Win for Communities And Your Capital Gains Tax Bill

Tax | Dec 06, 2018

The new tax law passed last December certainly has its boosters and its detractors, but it also has written into it something that appears to be a proverbial win/win. While this new provision does offer tax breaks to those among us who receive capital gains, to get those breaks the advantaged must invest those profits in funds that benefit the disadvantaged. The shorthand for all of this comes down two words: Opportunity Zones.

Read More

Opportunity Zones: A Win/Win for Communities And Your Capital Gains Tax Bill2019-03-29T16:59:18-04:00
Tax | Nov 26, 2018

Section 199A Deduction

Tax | Nov 26, 2018

The Tax Cuts and Jobs Act enacted on December 22, 2017, introduced Internal Revenue Code Section 199A. This new code section grants a deduction of up to 20% of qualified business income (“QBI”). It replaces Section 199 which was the Domestic Production Activities Deduction, beginning in 2018.

Read More

Section 199A Deduction2019-03-29T17:00:21-04:00