International Tax Blog
Welcome to the Sciarabba Walker International Tax Blog! We will be sharing original, informative, engaging content that examines a variety of international tax issues as they relate to individuals and businesses. Our International Tax Group stays up to date on the latest rules and regulations that affect our international tax clients. We are committed to assisting our clients on tax reporting issues related to the ownership of foreign assets, receipt of income from abroad, foreign financial transactions, and more.
Check out our blog for helpful tips, analysis, and examples of the issues that affect clients and how we are able to assist. And feel free to reach out to us anytime—we are here to help.
Disclaimer: The information in these blog posts is provided for general informational purposes only and is not intended to substitute for accounting, tax, or financial advice from a professional accountant. While we use reasonable efforts to furnish accurate and up-to-date information, we do not warrant that any information contained in or made available through this blog is current or error free. No part of this communication is intended to be used for the purpose of avoiding penalties under U.S. federal tax law.
The IRS recently announced that it will waive certain late-payment penalties related to the Section 965 transition tax. In addition, the IRS provided additional guidance for individuals subject to the Section 965 transition tax regarding the due date for relevant...read more
In a previous post, "What Happens When a Professor Goes Overseas on Sabbatical?", we discussed an example of a professor on sabbatical and looked at two options available to her: 1) use the foreign earned income exclusion, or 2) report all income as taxable and deduct...read more
The United States has almost 70 tax treaties with foreign countries covering income taxes and capital gains tax. These treaties delineate which country is entitled to tax an individual or entity in cross-border situations. But income taxes are only part of the tax...read more
As we have discussed in previous posts, while owning a foreign subsidiary has its advantages, it also presents complicated tax issues. We've analyzed the fictional relationship of U.S. Parent and foreign Sub and discussed the check the box rules, transfer pricing...read more
As mentioned in our previous posts, there are several U.S. tax reporting requirements for our fictional U.S. company “Parent” once it acquires our fictional foreign subsidiary “Sub.” As we discussed in our first post in this series, one of the Parent’s options is to...read more
In our previous post we discussed the initial considerations that fictional U.S. company “Parent” need to make after acquiring fiction subsidiary “Sub.” After the initial considerations are made and Sub is up and operating, the pricing of intercompany transactions...read more
As a business grows and becomes increasingly involved in different markets, having ownership of a company in a different country can provide many advantages. Ownership of a foreign subsidiary can be a great way for a U.S. business to expand into overseas markets and...read more
The following is an excerpt from an April 9, 2018, news release from the IRS: The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship, to check if they have a U.S. tax liability and a filing requirement. At...read more
For the past few weeks we explored the regulations on Passive Foreign Investment Companies (PFICs), discussed how they are taxed, and examined how certain rules determine ownership and affect reporting requirements. In this post we will discuss the tax impact of...read more
The IRS recently provided guidance for taxpayers affected by Section 965 of the Internal Revenue Code. In general, Section 965 requires U.S. shareholders to pay a transition tax on the untaxed foreign earnings of certain foreign corporations as if those earnings had...read more