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...
Mar 19, 2018 | Firm Updates, International Tax
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...
Mar 12, 2018 | Firm Updates, International Tax
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...
Mar 5, 2018 | Firm Updates, International Tax
Most tax issues can be difficult to navigate and understand; however, there is one set of regulations in particular that is especially complex. In the realm of international tax issues are the passive foreign investment company (PFIC) regulations, which came about as...
