Article written by FGMK Tax Partner Fuad Saba and Tax Manager Jill Boland

The Republican Party yesterday rolled out its proposed changes to the U.S. tax code, in what may become the most comprehensive overhaul of U.S. tax law since the 1986 Tax Act. The plan espouses four goals: (1) to simplify the tax code; (2) to lower taxes on American workers; (3) to entice companies to do business in the U.S.; and (4) to bring the offshore profits of U.S. companies back to the U.S. The proposed changes would impact the U.S. tax treatment of individuals, corporations, and certain cross-border transactions.

Read more: FGMK Tax Alert: An Overview of the GOP Tax Reform Proposal

Author: Matthew T. Fuller

The Multistate Tax Commission ("MTC") has just announced that it is going forward with a voluntary disclosure program for sellers on Amazon who have created nexus in a state because of their participation in the Fulfillment by Amazon ("FBA") program.  The MTC is an intergovernmental state tax agency that works on behalf of states and taxpayers to facilitate the equitable and efficient administration of state tax laws that apply to multistate and multinational enterprises.

What is the FBA Program and How Does it Create State Tax Nexus? 

Under the FBA program, sellers can list their products with Amazon and have Amazon hold their products at one of its warehouses before shipping products to the purchaser.  The presence of inventory in a state is sufficient to create nexus for sales tax, corporate tax, and personal income tax purposes, regardless of whether the seller has any other presence within the state where the inventory is stored.

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Non UK domiciliaries are only subject to UK Inheritance Tax (IHT) on their UK assets. Foreign assets are treated as excluded property, which are outside the scope of UK IHT while they are neither domiciled nor deemed domiciled in the UK (broadly once they have been resident in the UK for more than 15 out of the previous 20 tax years, under the proposed new rules).

It has been common practice for non UK domiciliaries to acquire UK residential property via a non UK company of which they are the ultimate beneficial owners. In doing so the owner was viewed as holding a foreign asset (the shares), which represented excluded property. Furthermore, the shares may have been settled on to a trust prior to the settlor becoming deemed domiciled in the UK and thereby preserving excluded property status for the future.

Read more: IHT exposure: Non UK domiciliaries and UK residential property

Contact: Donna Khoe

With the effective date for the super reforms fast approaching on 1 July 2017, there are numerous planning opportunities available before 30 June 2017.

We’ve set out a quick guide to assist you in surviving these reforms below:

Rule No 1 – Don’t panic!

While significant amendments have been made to the way superannuation funds are regulated in Australia, it is essential to remember that the majority of the key tax concessions (e.g. flat 15% tax on earnings) afforded to these superfunds remains the same which will continue to serve the core purpose of providing you with a better retirement.

Rule No 2 – Identify the reforms that is applicable to you

Not all of the changes announced will have an impact on you and your super member balance and it is important to focus on the ones that do affect you.

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Author: Hal Zemel, CPA, J.D., LL.M

While not exact, here is a simplified way to project your potential estate tax exposure.

  • Determine the value of your assets, net of any debts.
  • Subtract any assets that will pass to charity on your death.
  • If you’re married and your spouse is a U.S. citizen, subtract any assets you’ll pass to him or her. Those assets qualify for the marital deduction and avoid potential estate tax exposure until the surviving spouse dies.
  • The net number represents your taxable estate.

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