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Medicare tax on the sale of a principal residence?

Morrison & Foerster LLP
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USA
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October 13 2010

As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8 Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners

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Morrison & Foerster LLP
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USA
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March 31 2010

The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters

IRS memorandum: loan origination by foreign entity through U.S. intermediary subject to U.S. tax

Morrison & Foerster LLP
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USA
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December 31 2009

On September 22, 2009, the Office of Chief Counsel of the IRS released a generic legal advice memorandum, AM 2009-010 (“Memorandum”), concluding that interest income earned by a foreign corporation with respect to loans originated by an agent in the U.S., whether dependent or independent, is subject to net income tax in the U.S. as income “effectively connected” with the conduct of a U.S. trade or business

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Medicare tax on the sale of a principal residence?

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IRS memorandum: loan origination by foreign entity through U.S. intermediary subject to U.S. tax

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