July 2024 Hot Tax Topics

The Essential Tax Podcast with Mishkin Santa, Episode 7 In this episode of The Essential Tax Podcast, Mishkin Santa, Principal at Santa & Associates, covers recent tax updates including Australia's increased withholding tax, new IRS regulations, FBAR litigation, FinCEN BOI reporting, and potential French tax reforms. Mishkin, with a background in international tax and a former IRS Attorney, offers deep expertise on complex tax issues and frequently speaks at professional events. Tune in for these key takeaways: * Australia's Increased Withholding Tax: Australia’s plan to raise the capital gains withholding rate for non-resident sellers * IRS Regulations on Basket Contracts: The IRS’s new rules classifying “basket contract schemes” as listed transactions with additional disclosures and penalties * FBAR Litigation Updates: Recent rulings allowing juries to decide on the willfulness of FBAR non-filing * FinCEN BOI Reporting Requirements: The new requirement for U.S. LLC owners to file Beneficial Ownership Information reports * France’s Potential Tax Reforms: France’s proposed tax reforms, including citizen-based taxation and higher wealth tax, affecting both domestic and international taxpayers Further Resources:  * Australian Consultation Paper on Foreign Resident Capital Gains Withholding Rate: https://treasury.gov.au/consultation/c2024-550576  * IRS Proposed Regulations on Basket Contract Transactions: https://www.federalregister.gov/documents/2024/07/12/2024-14787/identification-of-basket-contract-transactions-as-listed-transactions  * United States v. Saydam, 22-cv-07371-DMR (N.D. Cal. Jul. 12, 2024): https://casetext.com/case/united-states-v-saydam  * FinCEN BOI Request for Beneficial Ownership Information: https://www.fincen.gov/news/news-releases/fincen-seeks-comments-information-be-collected-authorized-recipients-requesting  * FinCEN BOI Information Reference Guide: https://fincen.gov/news/news-releases/fincen-issues-notice-financial-institution-customers-beneficial-ownership  * France Beneficial Ownership Register Update: https://aboutbtax.com/be1u  * French Prime Minister Candidate Lucie Castets Major Tax Reform: https://www.connexionfrance.com/news/pm-candidate-wants-to-tax-french-abroad-as-america-taxes-its-expats/671310  * IRS Identity Theft Security Summit: https://www.irs.gov/newsroom/security-summit-urges-tax-pros-to-watch-out-for-identity-theft-red-flags  * IRS Tax Scams: https://www.irs.gov/newsroom/tax-scamsconsumer-alerts  * IRS High Income Audits: https://www.irs.gov/newsroom/irs-tops-1-billion-in-past-due-taxes-collected-from-millionaires-compliance-efforts-continue-involving-high-wealth-groups-corporations-partnerships  * IRS Required Minimum Distributions Final Regulations: https://www.federalregister.gov/documents/2024/07/19/2024-14542/required-minimum-distributions  * Finance Committee Chair Ron Wyden, D-Ore. - July 24 letter to UBS: https://www.finance.senate.gov/imo/media/doc/chairman_wyden_to_ubs_letter.pdf *********************************** Watch or listen to more episodes of The Essential Tax Podcast:  * https://www.youtube.com/@TheWolfGroupPC  * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944  * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa:  * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta  * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc  * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa