Summary: Tax-exempt and/or nonprofit organizations may be required to file form 5471. There are several instances where form 5471 would be required. Often, detailed analysis and thorough understanding of the tax rules are required to determine if there is a filing obligation. Failing to file (including late filing) for form is subject to a $10,000 […]
Assessment of FBAR Penalty to be Determined by the United States Supreme Court While there is no doubt that foreign or international tax obligations and reporting requirements are complex, recent cases and the US Supreme Court’s review of an FBAR ruling show that even US Federal Circuit Courts, the Internal Revenue Service and taxpayers […]
Hiring a Tax Attorney in Denver Before Tax Season Tax season is upon us again, and you may ask yourself if there are benefits of hiring a tax attorney in Denver. This means filing returns, paying taxes, and dealing with any issues that arise along the way. While many try to handle things themselves, doing […]
The McGuire Law Firm Business Attorney Denver Our Denver business attorneys are highly skilled and practice various transaction matters. They know how to guide businesses through the complexities of the law effectively. We can assist you with drafting contracts, negotiating deals, and resolving disputes. We advise on employment agreements, intellectual property issues, commercial leases, real […]
The IRS Streamlined Procedures Q&A’s There are many legitimate reasons United States persons may maintain foreign bank accounts or foreign assets. Perhaps an individual owns real estate in a foreign country, making payments via a foreign bank account easier. Alternatively, an individual has come to the United States for education and remained or married a […]
What Is Form 5471? The title of Form 5471 lays it out succinctly, “Information Return of U.S. Persons Concerning Certain Foreign Corporations.” It is the form used to report information about a foreign corporation where a US person owns an interest in the said foreign corporation. It sounds simple enough…. A taxpayer or tax practitioner […]
Excluding Gain Limits You may qualify for excluding gain from the sale of your home by up to $250k of your capital gains from your taxable income or $500k if you’re filing a joint tax return with your spouse. You must sell your principal residence before you can claim the exclusion. You can exclude gain […]
As discussed previously in other articles, reorganizations can provide a way to restructure business entities or acquire others without experiencing high tax costs. In other words, reorganizations offer ways to accomplish business goals through tax-free restructuring like a forward triangular merger. Common Use for a Forward Triangular Merger One standard method used is a forward triangular merger, or […]
Advantages of Taking on Debt with Non-Recourse Liability Non-recourse debt means that if the debtor defaults, the creditor cannot pursue the debtor personally. Instead, the creditor must seek recovery from the collateral securing the loan. The creditor can file a suit against the borrower if the collateral does not cover the debt. However, if the […]
What are Reorganizations? A reorganization allows a company to restructure its operations without triggering significant tax consequences. A reorganization is generally considered a change in the form of a corporation rather than a mere change in the place of doing business. For example, suppose a company moves its headquarters from New York City to Los […]