Accidental Americans and US Tax Compliance: A Discussion with the IRS

Flott & Co. recently had the opportunity to discuss our proposal for changes to the existing IRS “noisy” disclosure programs (Offshore Voluntary Disclosure Program – OVDP – and the Streamlined Filing Compliance Procedure for Non-Resident US Taxpayers – Streamlined Process) with representatives of the Service.  The discussion focused on encouraging the IRS to create a…

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The Inventor and the Tax Code

Section 1235 of the Internal Revenue Code (IRC) permits holders (Creators) “whose efforts created” the patent or holders (Investors) “who [] acquired [their] interest in such property in exchange for consideration in money or money’s paid to the creator prior to actual reduction to practice of the invention” to treat the transfer of “property consisting…

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