Professional Accounting Blog

    Accounting For Your Prosperity

    Allen Littman

    Allen is an attorney and a CPA who has an international tax practice focused on working and consulting with accounting and law firms, businesses, and investors on international tax planning, M&A, tax controversy, legislative and regulatory matters.

    Recent Posts

    Second Video in Tax Reform Series Decodes Individual and Domestic Provisions

    Posted by Allen Littman on Aug 7, 2018 11:47:34 AM

    In the first video of this series, we looked at several different perspectives on the international provisions of the new tax reform law. For this second installment, Allen and Pete will offer a bird’s eye view of the key provisions of tax reform.

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    New Expert Video Helps Solve International Tax & New Tax Reform Mysteries

    Posted by Allen Littman on Jul 17, 2018 10:17:00 AM

    With all the changes made in the recently enacted tax reform legislation, we could write a book. Instead, we thought sharing a video would be an easier way for our experts – who specialize in international tax services – to help take the mystery out of international tax laws and the new tax legislation, Tax Cuts and Jobs Act (TCJA).

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    Several Provisions of the Tax Cuts and Jobs Act (TCJA) Target Base Erosion and Inbound Investment

    Posted by Allen Littman on Jan 30, 2018 1:34:51 PM

    Topics: Tax Planning & Strategies, Accounting & Auditing

    New Rules Intended to Prevent Abuse of the New U.S. Territorial Tax System Also Target Foreign-Controlled Companies

    Background

    As 2018 unfolds, the fog of tax reform has cleared and we can now clearly see the many benefits of the U.S. Tax Cuts and Jobs Act.  Lower tax rates for businesses and individuals, increased expensing of business asset purchases, repeal of the corporate alternative minimum tax (AMT) and increase of individual AMT thresholds are just a few of the tax benefits now available to U.S. taxpayers.  For U.S. businesses owned by non-U.S. persons, however, it is a bit more of a mixed bag, as there are several unfavorable provisions.  These include several provisions ostensibly designed to prevent base erosion in the light of the new U.S. territorial tax system.  Many of these provisions, however, target foreign-controlled companies.  

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    New Regulations: Domestic Disregarded Entity (DDE)

    Posted by Allen Littman on Jan 31, 2017 3:24:43 PM

    Topics: Tax Planning & Strategies

    For tax and liability reasons businesses in the United States entities are designated as sole proprietorships, partnerships, limited liability corporations (LLC), and C and S Corporations for tax and reporting purposes. Each entity bears different responsibilities for reporting income and transactions, and individual owners have different obligations for the actions of their businesses.

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    Domestic Disregarded Entities will be Required to Report Information About Their Ownership and Intercompany Transactions

    Posted by Allen Littman on Jun 21, 2016 8:00:00 AM

    Topics: Tax Planning & Strategies

    U.S. Treasury Department Responds to Foreign Demands for Information Reporting

    Background

    For almost 20 years, the entity “check-the-box” rules have been a fixture of the tax law and a basic planning tool. They have simplified tax planning in numerous ways as well as creating a general road map for practitioners to repair damage caused by overly technical tax rules or their own technical mistakes. However, the dark side to check-the-box is that it has enabled both outbound and inbound avoidance and/or evasion.

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