fbpx

Author: Christopher Klug

Profile picture of Christopher Klug
About Christopher Klug
Christopher M. Klug serves clients with domestic and international taxation, tax controversy, corporate/business planning, mergers and acquisitions, cross-border transactions, and domestic and international estate planning needs.

Posts by Christopher Klug

Be Careful When the Terms of An Acquisition Seem Too Good to be True – They Usually Are

Posted on

When there is a cross-border merger and acquisition there are additional complexities to plan for, typical acquisition planning in one country may be different than in another country, and the resulting tax implications can be significant.  We have represented both the acquiror and target in a number of cross-border acquisitions and getting the right result requires a careful analysis of the tax implications involved.  What may seem like a very small detail may have very serious tax implications that greatly impacts the result of the acquisition for either the acquiror or target. […]

Read More… from Be Careful When the Terms of An Acquisition Seem Too Good to be True – They Usually Are

ERC – Voluntary Disclosure Program Overview (Employee Retention Credit Series)

Posted on

The ERC was first introduced in March 2020 to help employers retain employees through the Covid-19 pandemic. The IRS has made it a priority to recover wrongly claimed refunds through the ERC. Given the ERC required no formal approval process other than for the employer to file their employment tax returns or amended employment tax returns, there was huge potential for abuse. […]

Read More… from ERC – Voluntary Disclosure Program Overview (Employee Retention Credit Series)

Employee Retention Credit (Employee Retention Credit Series)

Posted on

The Employee Retention Credit (“ERC”) was first introduced in March 2020 to help employers retain employees through the Covid-19 pandemic.  The Internal Revenue Service (“IRS”) has made it a priority to recover wrongly claimed refunds through the ERC.  […]

Read More… from Employee Retention Credit (Employee Retention Credit Series)

Target Company: Be Careful in Changing its Tax Status Preacquisition at the Insistence of the Acquiror

Posted on

Target companies in mergers and acquisitions are often directed by the acquiror to change its tax classification preacquisition for U.S. tax purposes.  There are several reasons that an acquiror may request the target company to change its tax classification.  For example, the acquiror may not want an entity taxed as a c-corporation in its portfolio of companies.  […]

Read More… from Target Company: Be Careful in Changing its Tax Status Preacquisition at the Insistence of the Acquiror

Immediate Action to Apply for the ERC – Voluntary Disclosure Program

Posted on

It is important for employers who made questionable claims for the Employee Retention Credit (“ERC”) to take immediate action to determine whether the ERC Voluntary Disclosure Program (“ERC VDP”) is their best compliance option.  Since the ERC required no formal approval process other than the employer to file their employment tax returns or amended employment tax returns, there was huge potential for abuse that promoters heavily marketed. The deadline for an employer to apply for the ERC VDP is March 22, 2024.  […]

Read More… from Immediate Action to Apply for the ERC – Voluntary Disclosure Program

U.S. Taxation of Foreign Nationals Working in the U.S., Including Planning Opportunities

Posted on

As multinational corporations continue to expand their operations globally, they must navigate a complex web of tax regulations and laws. It is essential that they take a comprehensive approach to tax planning and not make decisions solely based on the U.S. tax implications. […]

Read More… from U.S. Taxation of Foreign Nationals Working in the U.S., Including Planning Opportunities

U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas

Posted on

U.S. citizens and U.S. tax residents (“U.S. Persons”) are taxed in the United States on their worldwide income no matter where in the world they reside. The U.S. taxes based on citizenship, which is different than almost all other countries in the world that tax based on residence.

This often catches U.S. Persons who have never lived in the U.S. or have lived abroad for a number years by surprise. Any U.S. Person living abroad with income for tax year 2022 above the following thresholds must file a U.S. tax return:
[…]

Read More… from U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas

Tax Implications of Exiting a Controlled Foreign Corporation

Posted on

The income of a foreign corporation is not subject to federal corporate income tax unless the foreign corporation has income that is effectively connected with a U.S. trade or business (or permanent establishment as provided in an applicable tax treaty) or consists of certain types of U.S. source fixed or determinable annual or periodic income (“FDAP”).  A foreign corporation’s income from operations outside the U.S. is not subject to U.S. corporate income tax unless special rules apply. […]

Read More… from Tax Implications of Exiting a Controlled Foreign Corporation

Connect With Us