Foreign Bank and Financial Accounts (FBAR) An FBAR filer according to the IRS is an individual that owns or co-owns with a spouse, a foreign financial account that requires the filing of an FBAR...
We recently posted that the IRS is requiring FBAR returns for Cryptocurrency Accounts as well as Online Gambling Accounts, in addition to the regular offshore banking accounts reporting. If these requirements are not complied...
by Fulton Abraham Sanchez, CPA · Published March 5, 2019 · Last modified April 23, 2019
The Trump’s Tax reform created a few tax benefits and tax charges for individual and companies doing business offshore. The benefits are aimed to encourage the repatriation of earnings accumulated in offshore companies and...
Hedge Funds and Private Equity
by Fulton Abraham Sanchez, CPA · Published March 1, 2019 · Last modified May 15, 2019
State Tax Implications Of federal Tax Reform It is a question of conformity with the IRC Rolling Fixed Selective Some provisions broaden the federal income tax base (e.g. interest expense limitations, Sec. 965 repatriation)...
Hedge Funds and Private Equity
by Fulton Abraham Sanchez, CPA · Published March 1, 2019 · Last modified May 16, 2019
Self-employment Tax In terms of the Self-Employment Contributions Act (SECA) individuals are subject to self-employment tax on their net earnings from self-employment derived from conducting a trade or business directly or indirectly through a...
Hedge Funds and Private Equity
by Fulton Abraham Sanchez, CPA · Published March 1, 2019 · Last modified May 14, 2019
The US GAAP requires that PE/VC investments must be stated at fair value.These funds (PE/VC) invest in private securities which are by definition iliquid. Securities include: Common stock Preferred stock with complex economic and...
by Fulton Abraham Sanchez, CPA · Published March 1, 2019 · Last modified May 16, 2019
The stress associated with a tax debt to the IRS is heavy to deal with many times. But instead of pretending time will solve it, you can be proactive and solve the problem. Don’t...
Hedge Funds and Private Equity
by Fulton Abraham Sanchez, CPA · Published March 1, 2019 · Last modified May 15, 2019
A Pass-Through Entity: To be or Not To be? The tax rate changes implemented as a part of the TCJA generally result in an increase in the rate differential on undistributed entity earnings...
For a non-U.S. person investment in U.S. real estate has to be carefully structured in order to create the most beneficial tax situation. Income during the ownership period , tax when selling the property...
by Fulton Abraham Sanchez, CPA · Published February 25, 2019 · Last modified May 15, 2019
Offshore Banking License in Puerto Rico In 1989 Puerto Rico (PR) adopted the International Banking Center Regulatory Act Number 52 (Act 52) to promote international banking to compete with the offshore banking centers in the...
