One of the constant gripes employees have about stock grants and stock options, particularly in small and start-up companies, is the tax cost to receiving what are supposed to be incentives to help contribute to the company’s success and increase the value for everyone. They are usually forced with a choice to either sell some or all of the stock to pay the tax or come up with the cash from other sources, a heavy toll and a disincentive to participation. Introducing: the Qualified Equity Grant – a new kind of plan designed to alleviate this problem and at the same time create a level playing field to keep the benefits broadly available.

The 2017 Tax Cut and Jobs Act (TCJA) had many provisions, which we will be discussing over the next few months, and they include good, bad, and ugly. Some are two-faced, with aspects that at first seem bad but may actually turn out to be a blessing depending on your situation. One such provision is the GILTI regime, a new category of “Subpart F” income intended to prevent inappropriate deferral of foreign source income by U.S. taxpayers.

On March 13, 2018, The Internal Revenue Service (IRS) announced that the OVDP will be ending September 28, 2018, and that any submissions not fully completed by that date will be rejected from the program. This means that anyone who has started but not fully complied with the documentation requirements by then will not be able to take advantage of the program and will instead be required to use the standard voluntary disclosure submission rules, which are not as friendly.

Until September of 2014 only companies that were contacted by the U.S. Department of Commerce were required to file information regarding foreign direct investment (FDI) on the Form BE-13. Effective September 15, 2014 this form is required when the FDI falls under one of five different categories, with an exception for anyone that doesn't fit into one these five.

The IRS just released revised instructions for the Form 8938 that impact what and who is required to report certain foreign financial assets.  The revised reporting generally only applies to tax years 2011 - 2014 and for tax years starting on or after 12/12/2014 it changes again.  There are two changes, one for who is required to report and the second is for what is required to be reported - both of which are the result of the final regulations.

I get this question a lot from clients who want to transfer money between their bank accounts, especially once the amount they need to transfer exceeds USD $10,000.  I think a lot of people know that transferring money in or our of an account in the U.S. over $10,000 is a reportable transaction, but what many people seem to misunderstand is that this is reported automatically by the bank.