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.
Owning a Foreign Subsidiary: What Else Is Required?
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...
Form 5471: What Category Do You Fall Under?
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...
Transfer Pricing: The Case for an Arm’s Length
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...
You’ve Acquired a Foreign Subsidiary: Now What?
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...
IRS reminds those with foreign assets about U.S. tax obligations
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...
PFICs: Dispositions and Purges
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...
IRS Provides Guidance for Section 965 Reporting, Tax Reform Updates
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...
Alert: Offshore Voluntary Disclosure Program Ending in September 2018
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...
PFICs: Look-Through Rules
In the previous posts we introduced the passive foreign investment company (PFIC) rules and discussed how they are treated for taxation purposes. We touched on how to determine if a fund is a PFIC and the most common type of PFIC. In this post we'll describe the...
PFICs: Taxation Methods
In our last post we introduced the complex international tax issues of passive foreign investment companies (PFICs) and gave a brief background on the regulations. In this blog post we'll briefly discuss the various methods of taxation and how to make certain...