Mar 14, 2019 | Firm Updates, International Tax
We recently posted a blog about foreign derived intangible income (FDII), a new deduction for certain domestic corporations. Since then, the IRS has issued proposed regulations for FDII under Section 250 of the Internal Revenue Code. According to the IRS, “The...
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...
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...
