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What is form 5471: Form 5471 is an information reporting form the must be filed with a taxpayer tax return when they meet certain ownership amounts of foreign corporations. Broadly speaking, the form reports who owns the foreign corporation, the current year financial information of the foreign corporation, information related to subpart F and GILTI...
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Form 926 | McGuire Law FIrm
What is Form 926? Form 926 is required to report transfers by U.S. persons to foreign corporations in an exchange described as a non-recognition transaction.  IRC Section 6038B gives rise to the reporting requirement for Form 926. The nonrecognition transactions that apply are: IRC Section 332 – Complete liquidation of corporate subsidiary, IRC Section 351...
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non profit organizations | Denver CO
U.S. tax compliance obligations for U.S. nonprofit (NP) organizations are generally fairly straightforward. If the entity is organized as a trust and operates as a pension fund, there may be no formal U.S. tax filing obligation (outside of Form 5500 with the DOL), assuming there is no unrelated business income (UBI). NP organizations may need...
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Business Lawyers in Denver Colorado
Business Lawyer in Denver Colorado | McGuire Law Firm Denver Business Lawyers You Can Trust If you’re looking for Denver business lawyers that you can rely on to look after your best interests, Mcguire Law Firm is here to help. Mcguire Law Firm has an experienced and trustworthy team of legal professionals dedicated to meeting...
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asset agreement
If you are considering purchasing, selling, or acquiring a business, whether it be through an asset purchase or stock purchase, the underlying agreement, and the obligations of the seller or the buyer to close on the transaction are likely to be contingent upon certain conditions. The timing of these contingencies to occur may be before,...
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So, assume you are a business owner who has worked hard to build a successful business, and now it is time to sell your business.  Or think you are looking to buy and acquire a business with plans to expand and grow the business.  Your attorney provides you with the stock or asset purchase agreement,...
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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...
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What is FIRPTA Withholding
FIRPTA, which stands for the Foreign Invest Real Property Tax Act, authorizes the United States government to tax foreign persons on the disposition of real property. The article below has been prepared by a Denver tax attorney to provide information related to FIRPTA. What is FIRPTA? If you are considered a foreign person for tax...
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Do You Know About IRC 368 Tax-Free Reorganization
IRC Tax-Free Reorganization Reorganization is a term used when a company changes its structure. A reorganization differs from a merger or acquisition because it does not involve merging two companies. Instead, it consists in changing the legal form of a corporation. Reorganization is also different from liquidating a company because it doesn’t involve selling all...
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