Author: praestansglobal

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Strategic Coordination of Accounting and Tax for the Family Office and Dynasty Trust

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Tax implications often determine how certain types of investors will invest in a fund.  There are various categories of investors that have competing tax implications so it is important that the fund can accommodate the competing tax interests of the investors.  One category of investors are tax-exempt investors and planning for unrelated business income tax (“UBIT”). 

A common planning strategy for tax-exempt investors to avoid UBIT is having a blocking corporation between the fund and the tax-exempt investors.  The blocker corporation is not tax-exempt and the income that flows through to the blocker corporation will be subject to corporate income tax reducing the return to the tax-exempt investors by the amount of the corporate income tax. […]

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U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas – Taxation and Reporting of Certain Foreign Assets

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or U.S. Persons with investments and income outside the U.S., the U.S. taxation can be unfavorable and there are enhanced informational reporting obligations.  For example, a non-U.S. pension that is taxed deferred in the country where the U.S. Person is a resident may or may not be taxed currently in the U.S. and the U.S. tax treatment will be based on U.S. pension rules.  Also, the non-U.S. pension plan will likely be considered a foreign trust which could require additional informational reporting. […]

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U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas – Foreign Bank Accounts

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The government does not annually tax wealth.  However, the IRS wants to know about funds U.S. Persons have in foreign bank accounts.  There are now two different reporting requirements for foreign bank accounts, the Foreign Bank Account Report (“FBAR”) and the individual reporting requirement under the Foreign Account Tax Compliance Act (“FATCA”). […]

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U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas

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U.S. citizens and U.S. tax residents (“U.S. Persons”) are taxed in the United States on their worldwide income no matter where in the world they reside. The U.S. taxes based on citizenship, which is different than almost all other countries in the world that tax based on residence.
This often catches U.S. Persons who have never lived in the U.S. or have lived abroad for a number years by surprise. Any U.S. Person living abroad with income for tax year 2023 above the following thresholds must file a U.S. tax return: […]

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Tax Filings for the International Executive

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Recently we were transitioning to take over the tax filing for an executive who was a U.S. tax resident because he had a green card but resided outside the U.S.  This executive has considerable income and the country that he resided in also taxed at higher rates than the U.S. federal income tax rates. Our review of the executive’s tax return not only found there were informational reporting errors, but that the income of the executive had been over reported by more than $160,000 […]

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Customized Mergers and Acquisitions Due Diligence Services

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In the acquisition of a business, it is important the buyer has a clear understanding of the target’s financial, commercial, operational, technical, human capital, and tax condition. Too often, certain parts of the due diligence do not receive the attention required, either because the firm performing the due diligence does not have the necessary background, or there is a lack of coordination among professionals in different fields of expertise. This is a critical opportunity for the buyer to learn of issues with the target as the nonidentification of key issues will have a financial impact down the road for the buyer. […]

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