Apr 30, 2018 | Firm Updates, International Tax
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...
Apr 24, 2018 | Firm Updates, International Tax
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...
Apr 9, 2018 | Firm Updates, International Tax
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...
Mar 26, 2018 | Firm Updates, International Tax
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...
Mar 23, 2018 | Firm Updates, International Tax
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...
Mar 22, 2018 | Firm Updates, International Tax
The Internal Revenue Service (IRS) recently announced that the 2014 Offshore Voluntary Disclosure Program (OVDP) will end on September 28, 2018. The advance notice is intended to give U.S. taxpayers with undisclosed foreign financial assets enough time to use the OVDP...