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Form 1042, 1042-S, & 1042-T Compliance Rules & Distinctions
Due to increased withholding reporting requirements for foreign persons, FGMK, LLC wants to ensure that its clients know about these filing requirements and that our International Tax team can assist. Form 1042 Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, is the form used to report tax withheld on …
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Biden-Harris Administration Rent Cap Proposal
The Biden-Harris Administration recently set forth a proposal aimed at corporate landlords with over 50 units in their portfolio. The proposal sets forth a plan to provide such landlords a choice: either cap annual rent increases on existing units at 5 percent or forego federal tax incentives, such as expedited depreciation. Recently, the Biden-Harris …
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Tax Legislation Clears House with Momentum as Heads to Senate
On January 31, 2024, the House of Representatives passed H.R. 7024 on a 357-70 vote. The $79 billion bill, referred to as The Tax Relief for American Families and Workers Act of 2024, entails updates to tax code provisions of significant interest to many taxpayers, as well as modifications to rules concerning the Employee Retention …
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Overview of Corporate Transparency Act
As of January 1, 2024, many companies now have to report beneficial ownership information (“BOI”) to Treasury’s Financial Crimes and Enforcement Network (“FinCEN”) which is a bureau of the United States Department of the Treasury, as required by the Corporate Transparency Act (the “CTA”), which was enacted in 2021 as part of the National Defense …
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The Corporate Transparency Act: – Beneficial Ownership Information of “Reporting Companies”
What is the Corporate Transparency Act (CTA) The CTA was enacted in 2021 to enhance the transparency in entity structures and ownership in an effort to combat money laundering, tax fraud, and other illegal activities. One of its key elements, beginning in 2024, will require all “reporting companies” to disclose certain beneficial ownership information …
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ARE STAKING REWARDS TAXABLE? MAYBE…
Earlier this summer (July 31, 2023), the Internal Revenue Service (IRS) released Rev. Rul. 2023-14. According to the ruling, cryptocurrency staking rewards are included in a taxpayer’s gross income at the time the taxpayer gains “dominion and control” over the tokens, not when the award is subsequently disposed. The ruling presents an example …
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U.S. TAX COURT RULING: IRS LACKS AUTHORITY TO ASSESS PENALTIES UNDER SECTION 6038(b)
On April 3, 2023, the United States Tax Court (“Tax Court”) issued a decision in Farhy v. Commissioner, 160 T.C. No. 6 (April 3, 2023) in which it determined that the Internal Revenue Service (“IRS”) does not have the statutory authority to assess penalties imposed by Section 6038(b) of the Internal Revenue Code (the “Code”). …
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FGMK Tax Alert – Secure Act 2.0 Impact to Qualified Retirement and 529 Plans
As part of the $1.7 trillion spending bill Congress passed and President Biden signed into law at year-end, a series of new laws—known collectively as Secure Act 2.0—has provided favorable changes to both qualified retirement plans and Section 529 plans. This FGMK Tax Alert provides a summary of these key changes. Changes to …
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Does Your Foreign Corporation Need a U.S. Tax Return?
Foreign corporations need to evaluate their U.S. activity to ensure they stay in compliance with the Internal Revenue Service’s filing obligations. Several factors, including the existence of a trade or business and nature of and extent of economic activities can impact or otherwise create a filing requirement. This FGMK article highlights key considerations for foreign …
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