Deal with U.S. Tax and Immigration Laws with Confidence with Seasoned International Lawyers
In today’s global business world the business of moving people, money, goods, and ideas throughout the world is growing fast, and demands that the international professionals that facilitate this movement, grow with them.
Professionals need to be knowledgeable and responsive without leaving behind the “old time” ideas and values of what it means to be a lawyer and solve the problem.
Whether you are an alien individual or foreign corporation investing in, doing business in, or moving to the United States or you are American investing and doing business outside of the United States or emigrating from the United States, you are going to deal with the U.S. tax and immigration laws.
Any lawyer involved in a clawback settlement agreement must, where possible, in the settlement agreement, distinguish between and earmark the two types of clawback that can happen. There can be a clawback of profits earned from the ponzi scheme or a clawback of invested principal. As you will see there is a distinctly different tax treatment between the two clawbacks and as a general rule, clawbacks allocated to profit losses may be more valuable for larger refunds but also may be more treacherous to deal with.
A video presentation of this content is available at no cost at www.USTaxLawSeminars.com
By Tax Attorney, Richard S. Lehman Esq.
PODCAST August 30, 2012: Update on two pieces of Tax Legislation that have been phased in over the last few years: The Foreign Account Tax Compliance Act (FATCA), and Foreign Financial Institutions reporting on Americans, plus the New I.R.S. Amnesty Program.
New I.R.S. program granting Amnesty from criminal tax prosecution for offshore delinquent taxpayers.
The I.R.S. has provided an open ended Amnesty Program for unreported income and unreported foreign accounts. The Amnesty Program must be handled by professionals who know what they are doing. There are legal safeguards and different levels of payments and taxes. There is a one time payment on Unreported Bank Deposits that can be assessed at penalties ranging from 0% to 27.5% of the Deposit. This program can be terminated at any time by the internal revenue service. Read Full Article by Richard S. Lehman, Esq.
The United States Tax Benefits Of Exporting: The Export Disc Corporation Computer Software And Internet Sales And Licenses
In a technical advice memorandum in 1985, the I.R.S. issued guidance on the issue of whether certain computer software programs constituted “export property” for DISC purposes. That Technical Advice Memorandum reviewed the term “export property” for DISC purposes in depth and determined in its holding that computer software could indeed be “export property”. In doing so the Technical Advice not only reviewed the legislative history of the DISC rules it also pointed out the distinctively different treatment that “patents, inventions, models, decisions, formulas, or processes whether or not patented, copyrights, goodwill, trademarks, trade brands, franchise or other like property” receive under the DISC rules, as opposed to the treatment of “films, tapes, records or similar reproductions, for commercial or home use.” Read Full Article by Richard S. Lehman, Esq.
The Foreign Account Tax Compliance Act (FATCA)
Americans now required to disclose all foreign financial assets. A specified person has an interest in a specified foreign financial asset if any income, gains, losses, deductions, credits, gross proceeds, or distributions attributable to the holding or disposition of the specified foreign financial asset are or would be required to be reported, included, or otherwise reflected by the specified person on an annual return. A specified person has an interest in a specified foreign financial asset even if no income, gains, losses, deductions, credits, gross proceeds, or distributions are attributable to the holding or disposition of the specified foreign financial asset for the taxable year. Read Full Article by Richard S. Lehman, Esq.
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