taxman

There is a concept of unrelated business income that applies to not for profit entities and in certain cases income from an RV could be taxable to the entity.

Thanks Keepm - I have always appreciated your perspective.

Joint audits with other countries coming, says IRS Commissioner In prepared remarks delivered on June 8 before the OECD (the Organization for Economic Cooperation and Development)/BIAC (the Business and Industry Advisory Committee to the OECD), IRS Commissioner Douglas H. Shulman said the groundwork was being prepared for joint country audits of multinational corporations. He also singled out the Foreign Accounts Tax Compliance Act (FATCA), which was enacted as part of the HIRE Act (P.L. 111-147), as the most important development in international information reporting in a generation and highlighted how it cracks down on Americans hiding assets overseas. Joint audits with other countries. Commissioner Shulman says IRS is now working on developing a protocol for joint audits with other countries. He stressed that a joint audit wouldn't be a simultaneous exam but, rather, two or more countries joining together to carry out a single audit of a company with cross-border business activities. Shulman sold the joint audit as a process that “will be more sensible and efficient for the participating business” because it will bypass two exam teams conducting two audits, and assure that both countries receive the same information and presentations from the taxpayer. The joint audits also will boost international tax compliance and improve service, according to Shulman. In theory, he said that with all the parties together hearing the same facts, they could more readily agree on the issues, jointly characterize a transaction, and agree on a treatment. This could reduce taxpayer burden, especially for large multinationals that would otherwise face audits in multiple jurisdictions on the same set of transactions. Joint audit could also provide tangible benefits to tax authorities, Shulman said, allowing them to adjudicate disagreements right away and reach a resolution through a much more efficient and effective process. Shulman revealed that work was underway on a “how to” guide for countries wishing to pursue a joint audit. Focus on FATCA. Commissioner Shulman characterized FATCA as the “most important development in international information reporting in a generation.” By creating transparency and accountability in the offshore financial markets, Shulman said that FATCA gives IRS the tools it needs to crack down on Americans hiding assets overseas. Shulman summarized FATCA as making it much more difficult for U.S. individuals to hide assets in offshore accounts by: · increasing information reporting by U.S. taxpayers holding financial assets outside the U.S. and imposing stiff penalties for failure to comply; · expanding due diligence standards, so that IRS has a better line of sight to U.S. beneficial owners of accounts; and · ramping up the stakes for foreign financial institutions that will “have to agree to disclose U.S. investors to IRS or feel the pain of a substantial new withholding tax on U.S. income and gains.” Shulman also believes that the mere enactment of FATCA should “prompt preparers and advisors to expand their due diligence regarding offshore account issues, including, but not limited to income tax reporting.” Shulman’s prepared remarks can be viewed on the IRS website at http://www.irs.gov/irs/article/0,,id=224121,00.html.

Levin introduces amendment to allow enforcement against offshore laundering Senate Permanent Subcommittee on Investigations Chair Sen. Carl Levin (D-MI), May 11, 2010, introduced an amendment (to S. 3217, the Restoring American Financial Stability Act of 2010) that would provide Treasury with discretionary authority to take measures against foreign financial institutions or foreign jurisdictions that impede U.S. tax enforcement. The text of the amendment provides that if Treasury determines that a jurisdiction or financial institutions operating outside the U.S. pose a money laundering concern or are otherwise impeding on U.S. tax enforcement, then Treasury could impose conditions on: the establishment in the U.S. of a correspondent account as well as the use of credit or debit cards. · the establishment in the U.S. of a correspondent account or payable-through account; as well as · the authorization, approval, or use in the United States of a credit card, charge card, debit card, or similar credit or debit financial instrument by any domestic financial institution, financial agency, or credit card company for or on behalf of a foreign banking institution. The news release and text of the Levin-Kaufman Package of Amendments Introduced to Stop Wall Street Abuses can be viewed at http://levin.senate.gov/newsroom/release.cfm?id=324847

I am a CPA and work frequently with estate and trust attorneys. Before you set up any irrevocable trusts recommended by certain people, check out this link: http://www.irs.gov/businesses/small/article/0,,id=106551,00.html (you may have to cut and paste the link) Pay special attention to the 5th question under Trust Taxation Questions as there are gift tax impilcations when contributing property to an irrevocable trust. Also, ask your own trust attorney if it is wise to be both the grantor and the beneficiary of such a trust as relates to protection from creditors. Hope this helps.

sounds good to me

Thanks for asking the question - the answers cleared things up for me

thanks for the info

4 - 12 months

Thanks for your effort and offering a different perspective.

Thanks for the posting - I missed the chat

Incredible amount of research, thanks so much!

Adam - thanks for all that you are doing.