Foreign Bank Accounts And Gifts To The Federal Government
Today we talk about common problems people run into with Foreign Bank Accounts, Trusts or Foreign Pension Plans. Also how, if you so desire, can make a charitable gift to the U.S. Federal Government. For questions regarding these or other tax issues you may have please contact me at 510-797-8661
Tax Planning Considerations
Tax Planning Considerations First Year Tax Issues Upon Becoming a US Resident If a married taxpayer wishes to file a joint return, both spouses must be residents at the end of the year and elect to be treated as U.S. residents for the entire year. If the taxpayer is taxed as a U.S. resident for…
Approaches to Valuing Cost Sharing Buy-Ins
Approaches to Valuing Cost Sharing Buy-Ins Buy-Ins: Introduction Buy-in payments are often associated with a cost sharing arrangement (CSA) transaction. See § 1.482-7 for regulations regarding cost sharing arrangements between related parties. Participants should receive arm’s length compensation (a “buy-in”) for “pre-existing” intangibles that are contributed to a CSA. The buy-in should be treated as…
IRS Says Its Auditors May Routinely Ask for Effective Tax Rate Reconciliation Workpapers
IRS Says Its Auditors May Routinely Ask for Effective Tax Rate Reconciliation Workpapers Chief Counsel Notice 2007-015 A Chief Counsel Notice concludes that effective tax rate reconciliation workpapers are neither tax accrual workpapers nor audit workpapers. As such, they aren’t included in the documents the IRS will not routinely request during an audit. Effective tax…
Millionaire Financial Calculator
Millionaire Financial Calculator What might it take to save one million dollars? This financial calculator helps you find out. Enter in your current savings plan and view graphically your financial results for each year until you retire! A complete report tells you when you could hit your Cool Million – and what you can do…