A Roth IRA can be an attractive investment over a traditional IRA in a couple of different ways: it gives taxpayers the opportunity to avoid tax on their IRA distributions and a Roth is not subject to required minimum distribution rules. When converting a traditional IRA to a Roth IRA, a taxable event occurs and taxpayers must pay tax on their conversion amount as if it were ordinary income.
With ever-growing globalization, wealthy families have taken the opportunity to live and maintain homes all across the world, including in the United States. One of the potential challenges facing such individuals is planning their estates in an effort to maximize tax efficiencies and to retain their hard-earned wealth.
The "Big Six" issued their "Unified Framework for Fixing Our Broken Tax Code". The framework is intended to give a template for the tax-writing committees to develop tax reform. The framework is also consistent with President Trump's four principles for tax reform.
Recent court decisions and the Internal Revenue Service (IRS) Chief Counsel Memorandum (CCM) reinforce the need to keep accurate records and adequately disclose all charitable contributions as well as gifts made to others.
The Internal Revenue Service has recently announced the launch of country-by-country (CbC) reporting pages on irs.gov which will provide background information on CbC reporting, frequently asked questions and other helpful resources, including a list of jurisdictions that have concluded competent authority arrangements with the United States.