by Greg BryantTax Incentive Programs in the Caribbean
By: Greg Bryant, CPA/Attorney Imagine, if you will, you live in California or New York City where your income tax rate is over 40% (federal and state). However, imagine then that you could move to another state, keep your US citizenship, and lower your tax rate to under 4% (federal and state). Would that be interesting? Well, here is how you can do it. The United States territories...
by Greg BryantTax Planning for Exports: IC-DISC Primer
By: Greg Bryant esq./CPA and Sarah Frazier, Esq. Although it has been in existence since 1971, the Interest Charge Domestic International Sales Corporation (“IC-DISC”) planning opportunity is often-overlooked. Since IC-DISCs began, IC-DISCs have been upstaged by a host of alphabet tax incentive regimes: Foreign Sales Companies (“FSCs”), Domestic Production (“DPD”), and Foreign Intangible...
by Lauren OlánEmployee Retention Credit
By Lauren Olán, Esq, LLM There are a lot of companies that have popped up recently promoting Employee Retention Credit (“ERC”) refunds, and in a frenzy to get to market, have contacted many companies to harvest ERCs, many times with little to no regard to whether the taxpayer qualifies. In this article, we unpack the rules, which are complex, to help taxpayers understand if they qualify...
by Greg BryantTax Planning in the Cannabis Industry: Section 280E of the Internal Revenue Code
By Gregory Bryant CPA/ Esq.Sarah Skinner, Esq. The green-wave is overtaking America. Cannabis is gradually reaching the masses, and consequently the mass markets, thanks to legalization efforts. As a reminder, marijuana and hemp are both cannabis. However, marijuana and hemp are different varieties of the Cannabis Sativia L. plant. Generally, hemp must contain 0.3% or less total...
by Sarah FrazierTax Considerations of Expatriating from the U.S.
By: Sarah Skinner, Esq, LLM and Gary Wells, Esq/CPA Since the November 2020 election, we have been getting a lot of questions about moving from the United States to Europe and the Caribbean. Generally, their concern is that income and estate taxes will increase under the Biden / Harris administration. We are also finding that Americans are more open to retiring outside America, in Ecuador,...
by Greg BryantNew IRS Offshore Account Program
OVDP offered taxpayers whose conduct was considered “willful” as to the nonreporting of foreign income with a path to compliance and more importantly an opportunity to diminish the threat of criminal charges they may face upon discovery by the IRS.
by Gary WellsThe Cybersecurity Threat, Burden, and Role of Tax Practitioners
Tax practitioners have learned that they possess something that a new breed of criminals, namely cybercriminals, desire—information.by Gary WellsStay Off IRS List and Secure Relief for Prior Nonreporting of Foreign Accounts and Other Assets
NOT TOO LATE to Stay Off IRS List and Secure Relief for Prior Nonreporting of Foreign Accounts and Other Assets (FBAR and others)by Gary WellsYearend Also Brings End to Startups Opportunity to Elect to Monetize R&E Income Tax Credit as Payroll Tax Credit for 2016
IRS and Department of Treasury provided operational rules for 2016 that allow at least for the 2016 tax year an extension of time for taxpayers to make the election on or before December 31, 2017 to treat R&E tax credits as a Payroll Tax Credit and claim the benefit against the next payroll tax filing.by Gary Wells