On March 21, 2023, the Treasury Department and the Internal Revenue Service (the “IRS”) announced that they were requesting comments regarding upcoming guidance on US tax treatment of certain nonfungible tokens (“NFTs”) as collectibles under Internal Revenue Code (IRC) section 408(m). NFTs An NFT is a unique digital identifier that is used to certify ownership and […]

The Inflation Reduction Act was signed into law on August 16, 2022. The tax changes in the law are a part of the “deficit reduction” provisions, Washington-speak for “tax increases”. The most significant tax increases are primarily aimed at the largest corporations. The bill will impose a new minimum tax on corporations with an average […]

One of the first questions posed to us by local advisors (investment managers, law firms, accounting firms, trustees) and by their clients is, What is the definition of a US Person for tax purposes? The US tax system imposes its income tax on “US Persons”; and the tax reaches all forms of income and gains […]

On 3rd March 2020, the Internal Revenue Service (IRS) issued Revenue Procedure 2020-17 (Rev Proc), which specifically covered an exemption from information reporting in respect of certain non-US retirement plans. To provide some context, US persons with an interest in a non-US “trust-based” retirement plan should consider filing Forms 3520-A and 3520 annually in respect […]

The IRS is targeting high-income taxpayers who have not complied with their tax obligations. As part of a larger effort to ensure compliance and fairness, the Internal Revenue Service said on February 19th that it will step up efforts to visit high-income taxpayers who have failed to timely file one or more of their tax returns. The IRS has recently hired additional enforcement personnel, […]

Please note, the IRS released an early draft Form 1040 for the 2019 tax year which contains a new item – 2019 Form 1040, Schedule 1, Additional Income and Adjustments to Income. The checkbox at the top of Schedule 1 asks taxpayers about their interests in virtual currency. Specifically, it states, “At any time during 2019, […]

The US Internal Revenue Service and US Treasury  have published what we regard as one of the most important sets of regulations to appear in some time – at least for anyone who happens to be a trustee of one or more trustee documented trusts; or who is  a compliance specialist with an institution such […]