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Entries tagged “Tax Law And International Tax”

Rimon Partner Susan Klein Recognized by Women in Tax Leaders by Euromoney’s International Tax Review, Again

News November 02, 2018
Rimon's Susan Klein was listed, for the third consecutive year, in Women in Tax Leaders by Euromoney’s International Tax Review. Women in Tax Leaders by Euromoney’s International Tax Review lists the women advisers who are making an impact in their specialized jurisdictions and industries. The women listed are clearly

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International Tax Attorney, Ajay Whittemore, joins Rimon as Partner in its San Francisco office

News October 25, 2017
Ajay Whittemore joins Rimon Law as a Partner in its Tax and Trust and Estate groups. Mr. Whittemore’s practice focuses on international tax planning and controversies. In the planning area, Mr. Whittemore advises clients regarding both inbound and outbound matters, including tax treaty analysis, transfer pricing, tax deferral opportunities,

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Congress Should Exclude Sales of Services From Any Remote Vendor Tax Collection Legislation. Bloomberg BNA , Daily Tax Report.

Insight August 14, 2015

No topic in the state tax world is more controversial than the potential imposition of sales and use tax collection responsibilities on remote vendors (i.e.,retailers lacking substantial nexus with the state at issue).

The dispute is loud and public, with battle lines that seem to offer no real hope for compromise. The states estimate that there will be an enormous increase in tax revenue if remote vendors are required to collect taxes on their sales; on the other hand, industry officials predict substantial adverse effects on remote vendors’ sales, coupled with unreasonable compliance costs.

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Key Highlights to Tax Professionals of New Offshore IRS Programs

Insight June 23, 2014
The Good News: The existing "Streamlined" procedure for non-resident, non-compliant taxpayers has been expanded significantly to permit many more non-filers to qualify for full abatement of penalties. Like the existing procedure, the new procedure (available here) requires taxpayers to file tax returns for the three most recent years and to

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Legal Evolution:  Serving Clients by Doing More With Less

Insight June 24, 2011

Law firms need to take a lesson from their business-clients by utilizing technology to become more efficient and cut costs to clients.

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Silicon Valley:  Connecting to Israel

Insight June 06, 2011

Recent moves into Israel by companies from the Silicon Valley are a reminder that there are still many untapped opportunities for economic cooperation between two of the world's foremost centers of high technology.  Innovative business cultures and common values make Israel and the Silicon Valley natural partners in the world of high-tech and venture capital.

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TAX ALERT - New IRS Amnesty for Offshore Accounts

Insight December 22, 2010

In his speech before the 23RD Annual Institute on Current Issues in International Taxation in Washington, DC on December 9, 2010, IRS Commissioner Douglas Shulman said that the IRS is “seriously considering” a new partial amnesty program for taxpayers who report secret offshore bank accounts.

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House Passes Changes to Carried Interest Taxation

Insight June 10, 2010

On May 28th, the House passed H.R. 4213, the "American Jobs and Closing Tax Loopholes Act." The Act addresses an array of issues, but has particular signficance for certain partnership and LLC "carried interests" for investment fund managers. If it goes through, the Act would prevent investment fund managers of venture capital, private equity, hedge and real estate funds from paying taxes at capital gain rates on investment management services income received as carried interest in an investment fund.

Under the proposed changes, return on invested capital in the form of carried interest would continue to be taxed at capital gain tax rates. But to the extent that carried interest does not reflect a return on invested capital, investment fund managers would eventually be required to treat seventy-five percent of the remaining carried interest as ordinary income.

The proposed changes would not take effect until 2011. However, for the bill to become effective it must also be passed by the Senate, an outcome which is not certain to occur.

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An LLC Can be Treated as an S-Corporation for Tax Purposes

Insight Michael Moradzadeh Michael Moradzadeh · February 02, 2010

An LLC can be treated as an S-Corporation for tax purposes if it makes an S-Corporation election as long as the entity meets the IRS criteria to be taxed as an S-Corp, files an S-Corp election and gets approved by the IRS to be taxed as an S-Corporation. Without an S-Corporation election, single member LLCs default to be taxed as sole proprietors and a multi-member LLCs defaults to be taxes as partnership since they are considered “disregarded entities”. However, if a single or multiple member LLC agreement meets the IRS criteria to be classified as a small business corporation, the S-corporation election is filed and gets approved by the IRS, then for tax purposes, not legal purposes the entity is an S Corp not a LLC.

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The Criteria for Being Classified as an S-Corporation

Insight Michael Moradzadeh Michael Moradzadeh · February 01, 2010

In order to be classified as an S-Corporation, a company must: be domestic, have no more than 100 shareholders, have one class of stock, all shareholders must be individuals, decedents’ estates, bankruptcy estates, trusts or tax-exempt charitable organizations, or wholly owned by another S corporation, and all shareholders must be residents of the United States (as defined by the tax code not immigration laws). Shareholders of an S-Corporation can not be financial institutions that use a reserve method of accounting for bad debts, companies taxable as insurance companies, taxable mortgage pools, or domestic international sales corporations. So, if a business entity meets these criteria it can be considered an S corporation by the IRS and taxed as an S corporation as long as the S corporation election forms are properly filled-out and approved by the IRS. Many states including California automatically give business entities an S-corporations tax status if it was approved by the IRS.

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