I often use Cornell’s Legal Information Institute (“LII”) to access tax regulations. I noticed that the HTML on the LII website included regulation examples in
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Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is: [A]s a logical matter, [the taxpayer’s] receipt of the TBL GmbH stock in exchange for the transferred intangible property was a precondition to [the taxpayer’s] distribution of that stock * * *. The distribution could not have occurred until the exchange of property for stock... Read more →
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Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2022. The number of published expatriates for the quarter was 1,474. See the chart below for the quarterly expatriates from 2011 to the second quarter of 2022. The 8-quarter moving average continues to be somewhat below 1,000 names per quarter. For our prior coverage of expatriation, see all posts... Read more →
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Yesterday the IRS published a new practice unit titled “Allowance of Deductions and Credits on 1120-F Delinquent Returns.” Under Code §882(c)(2), an untimely foreign corporation filer is not entitled to deductions and credits. However, Treas. Reg. §1.882-4(a)(3)(ii) permits the filing deadline to be waived. This practice unit explains the deadline waiver process. This new practice unit has been added to our Practice Units By Topic page. Read more →
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Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: Tax legislation is not a promise, and a taxpayer has no vested right in the Internal Revenue Code. Moore v. U.S., 129 AFTR 2d 2022-2046, (holding that the Section 965 Transition Tax did not violate the Constitution’s Apportionment Clause or the Fifth Amendment’s Due Process... Read more →
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I started my business in the later half of 2004. In early 2005, I had created a website and registered it with Google. However, when I performed Google searches (even for my specific name) there were no results. I felt like I didn’t exist on the Internet. Google published information on how it ranked websites and how to improve your search rankings. The most important factor was “inbound links” from quality websites. If other legitimate... Read more →
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Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is from a recent Sixth Circuit case holding that IRS Notice 2007-83 must be set aside because it did not satisfy the notice-and-comment procedures under the Administrative Procedure Act. The court stated: If individuals must turn square corners when they deal with the government, * *... Read more →
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I compiled some data on recent visitors to AndrewMitchel.com and Tax-Charts.com. The data is based on the past 12 months (May 2021 to April 2022). Charts on AndrewMitchel.com The top 20 charts visited on AndrewMitchel.com were as follows: Rev. Rul. 99-6, Situation 1 (Partnership to Disregarded Entity - Member Purchase) Rev. Rul. 99-6, Situation 2 (Partnership to Disregarded Entity - Third Party Purchase) Rev. Rul. 99-5, Situation 1 (Disregarded Entity to Partnership - Sale) Rev.... Read more →
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Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2022. The number of published expatriates for the quarter was 568. See the chart below for the quarterly expatriates from 2011 to the first quarter of 2022. The 8-quarter moving average has how now dipped significantly below 1,000 names per quarter. For our prior coverage of expatriation, see all... Read more →
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Yesterday the IRS published a new practice unit titled “Deferred Compensation Received by Nonresident Alien Individuals.” The practice unit discusses payments to NRAs from four types of deferred compensation plans: Salary deferral – unfunded deferred compensation plans under which U.S. taxation is deferred until payment is made. Distributions from a tax-qualified retirement plan (usually a pension or profit-sharing plan) of a U.S. company. Payments made by a U.S. company under an unfunded “top hat” retirement... Read more →
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