Many companies offer the option of sponsoring U.S. green cards for their employee(s) who may otherwise qualify to work in the U.S. under a nonimmigrant visa.
For individuals with international tax obligations, identifying and capitalizing on every foreign tax credit opportunity can be hugely complex. Key opportunities must be captured on the return without inadvertent oversights that can lead to significant risk.
Two private charitable endowments frequently used by high-net-worth taxpayers are Donor Advised Funds (DAFs) and private charitable foundations. Due to their popularity in recent years and potential for abuse, both have become areas of review for Congress.
In the aftermath of the COVID-19 pandemic when many art galleries were closed and art fairs and shows were canceled indefinitely, the latter are seeing a comeback across the United States and particularly in major art markets such as California, Florida and New York. The art pop-up provides both the burgeoning artist and seasoned art dealer a space to engage with art enthusiasts looking to expand their collection and first-time buyers who are stepping excitedly into the art world. Shows like the Superfine Art Fair in Los Angeles, Miami, New York City and San Francisco bring together over 130 emerging artists from across continents and targeted and prequalified buyers over a four-day period. Art Basel, held annually in Miami, provides a space for renowned and emerging art galleries to exhibit modern and contemporary pieces.
The Inflation Reduction Act of 2022 (the Act) passed by the House on August 12, 2022 and is now headed for President Joseph Biden's signature. The Act includes targeted business tax increases, funding for IRS compliance and enforcement, incentives to promote climate change mitigation and clean energy, and expansion of the small business payroll tax research credit. The measure extends for two years the excess business loss limitation for individuals, estates and trusts.
In November, Massachusetts voters will decide whether to approve a constitutional amendment to impose a 4% surtax on household income greater than $1 million.
Selling a business unit requires closely examining a myriad of potential commercial and financial outcomes. For state corporate income tax purposes, one of the most critical considerations is the unitary business principle.
Businesses that operate in more than one state are not only subject to each jurisdiction's tax but must also adhere to each state's rules for sourcing certain types of income.
When California issued Technical Advice Memorandum 2022-01 (February 14, 2022) (TAM 2022-01), it became the first state to adopt a tax policy that significantly weakens Public Law 86-272 (P.L. 86-272), which prohibits states from imposing income tax on certain out-of-state businesses that sell tangible personal property.
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