International Tax Blog

Blogs July 28, 2020 8 Areas You Should Review Under GILTI’s High-Tax Exception

U.S. shareholders can apply the new regulations concerning the GILTI high-tax exclusion, however, there are also disadvantages, and these eight review points can help determine if the election would be beneficial.

Blogs February 24, 2020 Previously Taxed Income Nuances Post-TCJA

Considerations regarding a post-TCJA repatriation, or “transition,” tax under Section 965 of the IRC as it relates to the accumulated profits in any specified foreign corporation.

Blogs August 15, 2019 New Form 5471 Proves Challenging for First-Time Filers

An examination of the considerations for first-time filers of Form 5471, used by U.S. Shareholders of Foreign Corporations to report the activity and potential deemed inclusions to those same shareholders.

Blogs June 21, 2019 Final Regulations Issued Under IRC Section 956

IRS final regulations that align the deemed income inclusion with the dividends received deduction (“DRD”), aka the participation exemption. It provides a treatment for earnings of a controlled foreign corporation (CFC) that are repatriated to a qual…

Blogs May 09, 2019 IRS Issues Proposed Regulations on Withholding Dispositions of Partnership Interests (IRC 1146(f))

The IRS released proposed regulations dealing with withholding under IRC Sec. 1446(f) “Special Rules for Withholding on Dispositions of Partnership Interests.” The proposed regulations generally follow the guidance provided in Notice 2018-29.

Blogs May 08, 2019 Royal Baby Archie Highlights Dual-Citizenship Taxation Issues

Is it financially worth it to have dual citizenship from the U.S. and another country? The Royal Baby will have the advantage of dual citizenship should his parents choose. However, will they take advantage of the sought-after American citizenship?

Blogs November 27, 2018 IRS Issues Proposed Regulations Related to Investment of Earnings in U.S. Property – IRC Sec. 956

The IRS issued proposed regulations addressing investment of earnings in U.S. property as it relates to controlled foreign corporations. These regulations were to address questions arising from various changes in tax law.

Blogs April 25, 2018 Cayman Islands BEPS Action 13 Reporting Requirements

The Cayman Islands is a member of the OECD's Inclusive Framework on BEPS. The Department for International Tax Cooperation (“DITC”), the Cayman Islands tax authority, published the Country-by-Country Reporting (“CbCR”) regulations.

Blogs March 05, 2018 8 Tips for Documenting Your Operations with Non-U.S. Persons

For payments and associated withholding relating to foreign persons, the IRS requires that Form 1042-S be completed. This form is similar to a Form 1099, but it specifically relates to a foreign person’s U.S.-source income.