United States: Fifth Circuit Affirms Decision Denying Installment Method Related To Sold Partnership Interests

In Mingo v. Commissioner, No. 13-60801 (5th Cir. 2014), the Fifth Circuit Court of Appeals affirmed the Tax Court’s holding (105 T.C.M. 1857) that the portion of a note attributable to unrealized receivables was not eligible for the installment method but that the taxpayer received basis in the note equal to the amount of the unrealized receivable recognized.

The taxpayer was a partner in a consulting business of PricewaterhouseCoopers LLP (PwC). In 2002, PwC sold […]

By |January 7th, 2015|

UK: Briefing Note: Taxable Remittance Outline

UK Resident Foreign Domiciliaries
Taxable remittances outline
Being a foreign domiciliary can have significant tax advantages and there may be opportunities for successful planning and arranging of affairs in a tax efficient manner. This is because the general position is that overseas income and gains not remitted to, or giving rise to a benefit received in, the UK are potentially not subject to UK tax. This briefing note provides a brief outline as to what constitutes […]

By |January 7th, 2015|

United States: IRS Releases Final Regulations For Reporting Of Specified Foreign Financial Assets

On Dec. 12, the IRS released final regulations under Section 6038D (T.D. 9706) relating to the provisions of the Hiring Incentives to Restore Employment (HIRE) Act that require specified foreign financial assets to be reported to the IRS for taxable years beginning after March 18, 2010.

The final regulations affect individuals required to file Form 1040 or Form 1040-EZ and certain individuals required to file Form 1040-NR or Form 1040NR-EZ.

The final regulations include guidance and […]

By |January 6th, 2015|