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Current Affairs

Why I stopped worrying about my tax practice and learned to love Trump’s tax plan


With the news that the Senate will allow a ratification of tax reform on a simple majority vote, there exists a larger than 50% chance that tax reform will pass this year. Loaded with stress and anxiety? I suppose I should be suffering these ailments as well, but I am not. I suppose I should join many large players are who actively fighting against reform because they fear a simplified tax code will reduce the need for their services. But I won’t. Why?

OVDP & offshore penalties CLE: Join me, Robert Hanson & Dennis Brager on November 1st.


Last year, Robert, Dennis, and I presented a CLE on "Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and Appeals." There have been a lot of developments since then --- both in the court room and internally at the IRS. But one thing hasn't changed: the IRS is incredibly aggressive, yet inconsistent, about assessing international penalties. We invite any tax practitioners concerned about keeping their international clientele safe from this real and present danger to join us.

FATCA is a blinding disaster that the 6th Circuit can't see. So let's help them.


**** UPDATE: We learned the the Sixth Circuit denied an En Banc Hearing September 27, 2017. So it's on the the Supreme Court. **** The US 6th Circuit of Appeals dismissed the Rand Paul/Mark Crawford Foreign Account Tax Compliance Act (FATCA) lawsuit for a lack of standing, claiming that it couldn't see the damage FATCA has caused. Yet we know the damaged caused is so obvious to everyone --- even its supporters --- that there has to be a logical way to explain the 6th Circuit's massive failure to see what everyone knows. One theory is that the FATCA disaster is so massive, like a atomic blast, it temporarily blinds certain observers, making them unable to make use of their faculties. In this article, we will help anyone so confused to make sense of FATCA. We will focus on just one example, just one victim of FATCA, Donna-Lane Nelson. Ms. Nelson is a plaintiff in the FATCA lawsuit. She tells us her story in detail and talks about how FATCA robs opportunity from regular Americans every day.

Should I file a Streamlined Submission or use the Full OVDP?


Too many people, realizing they have a problem with issing FBARs, Form 8938 and income overseas panic. They go to and become convinced that they need to enter into the full Offshore Voluntary Disclosure Program (OVDP) --- or else. The problem is that once you go full OVDP, you can't go back, even if the Streamlined program was the most appropriate choice. In this article we will add some perspective on who should use the full OVDP and those who should use the Streamlined program.

Australian Superannuation US tax treatment: Separating fact from (wishful) fiction


US persons are taxed on their worldwide income, even if there is income generated in a tax-deferred account in another country. This is especially a problem for US Expats in Australia, and for Australian immigrants to the US who still have assets that earn income overseas. We recently came across an article claiming that the entire US tax industry is treating all Australian Superannuation funds incorrectly. And the writer of the article claims he has the best solution. No doubt the entire US tax treatment of Australian Superannuation Funds held by US persons is complicated and can be onerous. However, some cases are actually pretty simple. In this article we analyze the claims made and help clarify the issues so that the US holder of an Australian Superannuation can be empowered to make up their own minds if they have a big issue or not.

What is the Carried Interest Loophole?


There is actually no such thing as the Carried-Interest Loophole. Try as one might, it is impossible to find a special tax rule that allows Hedge Funds and Hedge Fund managers to take advantage of the US tax code in a way that no other investor can. In this article we will explain the rules, and why any attempts at closing the non-existent loophole would necessitate the removal of long terms capital gains treatment --- something that is completely infeasible.

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