Ellis Ellison

When someone asks what is outdoor furniture, they are referring to a very broad category that covers a vast array of unique items. Some people think of wicker or rattan pieces as being the most popular, but there are so many other types that fall under this umbrella that it

Thus, for instance, a § 401(k) secure harbor plan with a plan year starting July 1 might operationally adjust to § 2112 of SBJA through the plan 12 months starting July 1, 2010 (for distributions made after September 27, 2010) and the plan year beginning July 1, 2011, with out having

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The IRS presumes that a foreign financial asset has sufficient value to meet the reporting thresholds if a Form 8938 isn't filed, and if it determines that a taxpayer owns one or more foreign financial assets that are required to be reported. Penalties can be waived if the taxpayer can

When you want a new garden set for your children or grandchildren, buying one is a great idea. However, the cost can be overwhelming. If you know what to look for and where to look, you can find a good deal on a garden set for sale that will provide

Under FATCA, certain U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on Form 8938, Statement of Specified Foreign Financial Assets. There are serious penalties for not reporting these financial assets . This FATCA requirement is in addition to the long-standing requirement to

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Shareholder of a CFC with GILTI income that is subject to a 25% foreign income tax would incur tax in excess of 55% after considering federal, state, and Net Investment Income taxation. The 962 election and the benefits of the Section 250 deduction may not be a panacea for all

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Our international tax lawyers have detailed knowledge of the U.S. federal income tax laws applicable to both outbound investments and activities of U.S. taxpayers and inbound investments and activities of foreign taxpayers. For outbound investments and activities of U.S. taxpayers, the applicable U.S. federal income tax

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Many of the financial aid programs available to students can be described as "Firpta Exemptions"Federal Pell Grant Exemptions." In other words, they are specifically designed to help people who have less than perfect credit. They provide free money for those with a lot of financial need. The money is

Similar to FIRPTA deposits, if the taxes owned are less than the tax amount withheld, the seller gets a refund. Sate withholdings are different from FIRPTA’s federal withholding requirements. In order to cover taxes that sellers may owe, some states ask buyers to withhold a supplementary amount. This is

Also, depending on the countries involved, there may be treaty benefits available that could reduce the worldwide effective tax rate on the disposition. Two of the most important considerations for non-US companies disposing of US real estate are withholding under the Foreign Investment in Real Property Tax Act and available

Switzerland is not immune to these developments - or their far-reaching consequences. We help Canadian citizens make investments in U.S. businesses, real estate properties and other U.S. investment vehicles. There are a number of strategies that can help minimize the amount of tax that must be paid by

Once you arrive within the US attempt to avoid making ANY change or performing any transaction in your super, and get tax advice if you're approaching your preservation age. In addition, the foundations would require that any GRAT remainder (the quantity to which a present would apply) should be the

MR. HOFFMAN: What did you consider Steven Miller’s comments final week that he’s undecided that FATCA’s advantages will outweigh its prices, which had been followed, I believe, followed shortly thereafter, by Nina Olson’s feedback considerably along a similar vein, involved about the associated fee versus benefits

Before entrusting someone with your private financial and personal information, do some research on their qualifications. The IRS has a searchable database where you can verify the background and credentials of your income tax preparation professional. Once you have selected someone, ask about their service fees and confirm their availability.