It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.
It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.
It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.
The controlled foreign corporation statute is a bedrock legal concept of U.S. international taxation. Enacted in the early 1960s, it is one of the most complex statutes in the U.S. tax code.
“An Introduction to Controlled Foreign Corporations” will provide the CPA with an overview of this statute.
The controlled foreign corporation statute is a bedrock legal concept of U.S. international taxation. Enacted in the early 1960s, it is one of the most complex statutes in the U.S. tax code.
“An Introduction to Controlled Foreign Corporations” will provide the CPA with an overview of this statute.
It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.
The controlled foreign corporation statute is a bedrock legal concept of U.S. international taxation. Enacted in the early 1960s, it is one of the most complex statutes in the U.S. tax code.
“An Introduction to Controlled Foreign Corporations” will provide the CPA with an overview of this statute.
Today, more and more companies’ and individuals’ tax matters cross borders. These multi-jurisdictional transactions and structures are typically governed by tax treaties. Although there are three basic model treaties (the OECDs, the US’ and the UNs), each uses many of the same concepts.
Hale Stewart is teaching 2 upcoming webinars next week that offer CPE credits: An Introduction to U.S. International Tax and Introduction to Captive Insurance. If you are serious about continuing your tax education, you should register with haste. Scroll down to read descriptions about the classes offered.
Hale Stewart is teaching 2 upcoming webinars next week that offer CPE credits: An Introduction to U.S. International Tax and Introduction to Captive Insurance. If you are serious about continuing your tax education, you should register with haste. Scroll down to read descriptions about the classes offered.
Starting in the mid-1970s, and continuing through the UPS case, the IRS fought captives tooth and nail. Over the course of these cases, they advanced three different legal arguments against captive insurance: the economic family argument, the nexus of contracts and the assignment of income doctrine.
While captive insurance companies have been used by large companies for over 60 years, their use by small and medium sized companies is still in its infancy. There are numerous reason for this, but perhaps the most important is the simple lack of knowledge.
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