I thought it would be inappropriate to continue my “Hurricane Harvey and Captive Insurance” series while Florida was dealing with Hurricane Irma. But now that the worst is over, I wanted to continue my train of thought. Last week, I showed that controlling the claims process is an incredible advantage to owning a captive. This is especially beneficial during a large catastrophe because your captive won’t be flooded with non-parent company claims, slowing down the settlement process. Read More
The Importance of Controlling the Claims Process
I live in Houston, Texas. And while the last few weeks have been understandably difficult, I could not be prouder of my city or state. Watching the first responders work tirelessly for days was awe-inspiring. Seeing large numbers of people risking their lives to help rescue their fellow citizens was one of the greatest acts of selflessness I have personally witnessed. Kudos should also be given to numerous city, county, state and federal employees who swiftly and efficiently responded to the disaster. Read More
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.
The content of the webinars presented on www.taxconnections.com is important! We just received a very nice message from Rajendra Singh who attended the “Captive Insurance For CPAs” taught by Hale Stewart last week: “I enjoyed your webinar yesterday. You will make one of the best-liked teachers on any campus. I bought your book on Captives.”
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.
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