By: Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq., Associate Brent Conrad For tax purposes, a non-U.S. citizen is either a nonresident alien or a resident alien. All aliens are considered nonresident aliens, unless they pass the green card test or the substantial presence test. A person meeting either [...]
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By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate Several news outlets this week report that the U.S. State Department confirms that it has already acted on its part in the process and denied passports to an undisclosed number of taxpayers. Reports also confirm that the IRS [...]
By: Eli Noff, Partner and Mary Lundstedt On April 3, 2018, in United States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government's suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of [...]
By: Eli S. Noff, Partner & Mary Lundstedt The recent Tax Court's Alterman v. Commissioner decision is a lesson in Accounting 101 for Cannabisseurs. Well, technically it's a valuable lesson about record-keeping to all taxpayers who are subject to Internal Revenue Code (I.R.C.) §280E-but with the currently high audit rates for the marijuana industry, [...]
By: Eli Noff, Partner & Mary Lundstedt On June 21, 2018, the Supreme Court delivered its highly anticipated decision in South Dakota v. Wayfair, Inc., et al. The 5-4 decision discards the antiquated "physical presence rule" - a rule which has allowed retailers lacking a physical presence in a state to avoid any obligation [...]
How Do Tips Affect Taxes Florida Taxes? Many of us who work in service industries such as restaurants and hotels, depend heavily on tips to supplement our income. Tips are essentially payments customers make at their discretion for services they receive from employees. Tips may be in the form of [...]
By Mary Lundstedt "If you’ve ever been tempted to buy into a hot investment opportunity linked with luxury travel, the Securities and Exchange Commission has a deal for you." Sound too good to be true? It is. This announcement was made in the May 16, 2018 U.S. Securities and Exchange Commission [...]
By Mary Lundstedt On May 23, 2018, the IRS issued Notice 2018-54, making it abundantly clear that when it comes to state efforts to circumvent the recently enacted state and local tax (SALT) deductions cap, "taxpayers should be mindful that federal law controls the proper characterization of payments for federal income [...]
By Eli Noff, Partner & Mary Lundstedt, Esq. On May 16, 2018, in United States v. Colliot, the District Court for the Western District of Texas held that the Internal Revenue Service (IRS) is precluded from assessing a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty exceeding the $100,000 [...]
By Mary Lundstedt , Esq. In November of 2017, Coinbase, Inc. ("Coinbase"), a company that facilitates digital currency transactions, was ordered to comply with an IRS summons demanding specific Coinbase client identifying information and transaction data for Coinbase accounts "with at least the equivalent of $20,000 in any one transactions type" [...]