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Foreign Corporate Reorganizations and Financial Planning

Overview of Reorganizations

Reorganization is a transaction aspect of foreign corporate entry and exit activity that can have great importance in the considerations accompanying financial planning. To provide an adequate foundation to the fundamental understanding of reorganization considerations, a cursory overview of basic domestic, reorganization concepts is helpful.

These concepts can be divided into three types of reorganizing transactions. First, there are reorganizations deemed to be exiting the taxing jurisdiction of the United States. Second, reorganization transactions occur in the transnational process of the reorganization of a foreign corporation within a United States taxing jurisdiction. This would be a transaction Read More

Written by | Posted in Corporate • International

VAT Consequences For I.T. Companies In Ireland – Part V

One of the biggest problems envisaged with the MOSS systems is identifying the location of the customer.

It is essential for suppliers to correctly identify the customer’s location/permanent address/usual residence so they can charge the correct VAT rate applicable in that member state.

For most telecommunication, broadcasting and electronically supplied services, it will be obvious where the customer resides. The decision about the place of supply of those services should be supported by two pieces of non-contradictory evidence including credit card details and a billing address for example. Read More

Written by | Posted in TaxConnections

A Collection… The Humorous Side of Tax… (10)

♦ An estate & trusts lawyer was reading out the will of a rich man to the people mentioned in the will: “To you, my loving wife Rose, who stood by me in rough times, as well as good, I leave the house and two million.” The lawyer continued, “To my daughter Jessica, who looked after me in sickness and kept the business going, I leave the yacht, the business and one million.” The lawyer concluded, “And, to my cousin Dan, who hated me, argued with me, and thought that I would never mention him in my will well you are wrong. “Hi Dan!

♦ An accountant, a tax attorney and an actuary were dining together at a fashionable restaurant.

“With income tax being so complicated, we accountants are all doing quite well these days,” Read More

Written by | Posted in Tax Humor

20 Jurisdictions Treated as Having an IGA in Effect and 10 Day Extension for FFI Registration Granted

Foreign financial institutions (FFIs) and US withholding agents (USWAs) have presented compliance concerns to Treasury and the IRS about the status of FFIs in jurisdictions that are known to be in an advanced stage of concluding an IGA, but have not yet signed such agreement.  Treasury has signed IGAs with 26 jurisdictions and has reached agreements in substance or is in advanced discussions with many others.

Treasury and the IRS have on April 2, 2014 issued Announcement 2014-17 to provide some level of comfort to FFIs in such jurisdictions that already have reached an IGA in substance and to USWAs paying agents.

Moreover, the IRS has also granted an extension of 10 (ten) days, previously April 25 but Read More

Written by | Posted in FATCA • IRS

The Senate Finance Committee Agrees to Expand the Federal-Level Research & Experimentation Tax Credit for Certain Small Businesses

On April 3, 2014, The Senate Finance Committee agreed to expand the Federal-Level Research and Experimentation Tax Credit (hereinafter “RTC”) for certain small businesses, making the tax incentive available to companies that don’t have an income tax liability.

The change, pushed by Senator Chuck Schumer (D-N.Y.) and other lawmakers on the Hill, proposes to make the RTC available to many start-up companies that typically aren’t able to claim it during their first years in operation, as Senator Chuck Schumer indicated at the Finance Committee’s markup on expired tax incentives. Senators across both sides of aisles approved the proposal on a voice vote, with no objections.

Pursuant to the currently expired statute, companies can take the RTC only if they have Read More

Written by | Posted in R&D Credit Services • Small Business
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