Jun 19, 2018 | Firm Updates, International Tax
The United States has income tax treaties with many different countries. These treaties allow for various forms of tax relief or exemption from tax for U.S. citizens and permanent residents. Some examples of treaty benefits are reduced tax rates, exemption from U.S....
Jun 13, 2018 | Firm Updates, International Tax
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...
Jun 11, 2018 | Firm Updates, International Tax
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...
Jun 4, 2018 | Firm Updates, International Tax
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...
May 14, 2018 | Firm Updates, International Tax
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...
May 7, 2018 | Firm Updates, International Tax
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...
