- Posts by Kenneth S. Levinson
Of CounselKen is a recognized transactional tax attorney who advises businesses, investors, and multinational organizations on international tax planning, tax-efficient transaction structuring, and complex business tax matters. He ...
For more than 50 years, the IRS provided various procedures for taxpayers who had failed to file their required “Report of Foreign Bank and Financial Accounts” (FBARs) on FinCEN Form 114 under the U.S. Bank Secrecy Act. However, on July 1, 2026, the IRS quietly removed the webpage from its website that was dedicated to those DFSP Procedures.
If you have been concerned about how the OECD’s “Pillar 2” proposal would apply to U.S. companies and their foreign affiliates, you are not alone. For years, since the OECD initiated its BEPS project in 2015, a key issue was how the international community would stop the ubiquitous efforts by multinational companies to allocate material profits to low or no tax jurisdictions, hence reducing their worldwide tax obligations.
On Thursday, June 20, 2024, the Supreme Court handed down its long-awaited tax decision in Moore v. U.S. And, an interesting set of opinions it is (all 83 pages of them)!
The U.S. Supreme Court will hear another tax case in the upcoming 2023-2024 session. This one, Moore v. United States, is a doozy...
The Supreme Court accepted United States v. Bittner for certiorari on June 21, 2021, and the case will be argued on Tuesday, November 02, 2022.
If you are into Foreign Bank Account Reports (FBARs), your concern about penalties for failing to comply with those FinCEN 114 reporting rules just took an exciting, and perhaps fearsome, turn.
This week, we turn to international transactions that involve licenses or the provision or performance of e-commerce services.
The transfer or use of intangibles generally is a complicated area of taxation, and one that continues to evolve.
Last week, we reviewed the basics about captive insurance companies, nonadmitted insurance and the essence of the federal legislation known as the NRRA. This week, we examine what the states did to implement NRRA and how that affected, or may affect, insurance premiums paid to out-of-state captives.
We are seeing increased focus by state tax departments on nonadmitted insurance premium reporting, tax payments owed and auditing of captive insurance companies. This article is Part I of our primer on the application of the nonadmitted premium tax rules to purchases of insurance from out-of-state captives.