Steve Goldman

Steve Goldman

Tax Technical Specialist, ONESOURCE Trust Tax. JD, LLM, Boston University School of Law.

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IRS Postpones Information Reporting by Domestic Entities for Specified Foreign Financial Assets

On January 23, 2013, the IRS issued Notice 2013-10. The Notice postpones the date that domestic entities, including trusts, will be required to report their interests in specified foreign financial assets on Form 8938. Background Code § 6038D was enacted by section 511 of the Hiring Incentives to Restore Employment Act (the … Read More

Regulations Require Updating of Employer Identification Numbers

On May 3, 2013, the IRS issued final regulations that require any person assigned an employer identification number (EIN) to provide updated information to the IRS in the manner and frequency prescribed by forms, instructions, or other appropriate guidance.  These regulations affect persons with EINs and will enhance the IRS’s ability to maintain … Read More

IRS Releases Draft Form for Medicare Surtax on Net Investment Income

On August 6, 2013, the IRS released a draft of 2013 Form 8960, Net Investment Income Tax – Individuals, Estates, and Trusts.  Taxpayers use the form to compute the 3.8% surtax on net investment income, added by the 2010 Health Care Act.  The IRS has not yet released instructions to the form. The IRS … Read More

New Canadian Withholding Tax Documentation Requirements

The Canada Revenue Agency (CRA) has changed its procedures for determining whether non-residents can claim a reduced rate of withholding tax under a tax treaty. Background Canada imposes a 25% withholding tax on certain types of Canadian source income paid to nonresidents of Canada.  Residents of countries with which Canada has a treaty may be … Read More

Federal district court in Arizona issues final decision in demutualization case

On April 19, 2013, the federal district court in Arizona issued a final decision in the Dorrance case.  2013 WL 1704907.  This follows a preliminary decision in July, 2012.  See our previous bulletin, “Open Transaction Doctrine does not apply in insurance company demutualization case,” July 16, 2012. Background: A mutual insurance company has no … Read More

Open Transaction Doctrine does not apply in insurance company demutualization case.

On July 9, 2012, a federal district court in Arizona ruled that the taxpayer could not apply the “open transaction” doctrine in a case involving stock received from an insurance company that demutualized. Background. A mutual insurance company has no shareholders.  Instead, the policyholders have an ownership interest in the company, in addition to having … Read More