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Tag Archive for international

International Tax Partner Opportunity (Midwest Region)

Tax Partner International 29

TaxConnections has been retained by a world class multinational law firm to locate a Tax Partner to lead the Chicago and Midwest region in serving international and transfer pricing clients. Due to the continued expansion of the international practice our client is searching for an individual who is currently with a Big Four firm or multinational law firm. The Tax Partner will team with a group of talented individuals who are already in place to grow the tax practice. The law firm currently has about 80 tax lawyers worldwide and are seeking the lead person in the midwest law practice. This successful practice is expected to double in size over the next five years.

The Tax Partner will assist multinational clients to design, develop, implement, document and defend international and transfer pricing strategies. They will provide clients guidance in analyzing factual material, communicate the benefits of the transfer pricing methodologies both to government representatives and the courts and negotiate advance pricing agreements on a worldwide basis.

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Transfer Pricing/International Tax Partner – Midwest Law Firm

Tax Partner With Midwest Law Firm

TaxConnections has been retained by a leading multinational law firm to locate a Tax Partner to lead the Midwest region in serving transfer pricing and international clients. This market facing role is due to the continued expansion of the international and transfer pricing practice. The Tax Partner will team with a group of talented economists who are already in place to grow the Midwest tax practice. The law firm currently has about 80 tax lawyers worldwide and this successful practice is expected to double in size over the next five years.

The Tax Partner will assist multinational clients to design, develop, implement, document and defend transfer pricing strategies. They will provide clients guidance in analyzing factual material, communicate the benefits of the transfer pricing methodologies both to government representatives and the courts and negotiate advance pricing agreements on a worldwide basis.

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Canada Revenue Agency – Important Dates for 2018

Canada Revenue Agency (CRA) has a number of dates and deadlines of importance to corporations. Failure to comply with these deadlines may raise a red flag with CRA, which in turn may trigger an audit.

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Foreign Freelance Income & What Does Maradona Have To Do With It?

Just when I was planning on publishing my post on foreign free lance income and tax consequences- the big news headline of 2017 dropped! Today special prosecutor, Robert Mueller brought charges against Manafort & Gates for money laundering and foreign bank accounts among any other things. While those fireworks continue and you think that you may not be in the same league as them, let me assure you that many U.S. citizens who live abroad and have freelance income do not understand its tax implications.

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SEC Obtains $58 Million Judgment Against Perpetrator of International Pump-and-Dump Scheme Involving Marley Coffee

William Byrnes, Tax Advisor

The Securities and Exchange Commission obtained a $58 million judgment against a UK and Canadian resident charged with perpetrating a multi million-dollar, international pump-and-dump scheme involving the stock of Jammin’ Java Corp., a company that used trademarks of the late reggae artist Bob Marley to sell coffee products.

The final judgment against Wayne Weaver, entered on October 2, 2017, permanently enjoins Weaver from violating Section 5 of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Section 13(d) of the Exchange Act and Rules 13d-1 and 13d-2 thereunder; permanently bars Weaver from participating in penny stock offerings; and orders Weaver to pay disgorgement of $26,371,585, prejudgment interest of $5,221,809, and a civil penalty of $26,371,585, for a total of $57,964,979. On September 15, 2017, Weaver filed a notice of appeal.

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Getting An ITIN Abroad – What American Expats Need To Know

Hugo Lesser

ITIN, Individual Taxpayer Identification Number, is a 9 digit number that is issued by the IRS that allows individuals who are not eligible for or who don’t have a social security number to file a U.S. tax return. Before such individuals can file their U.S. tax return though, they need to apply for an ITIN.

It’s important to note though that ITINs don’t qualify their holders to work in the U.S. or claim U.S. Social Security benefits; they are simply used to file U.S. taxes. Read more

Establishing Same Country Exemption Through Legislation

John Richardson

The Maloney Approach

This is a continuation from a previous article, FATCA’s Same Country Exemption Won’t Work.

On April 25, 2017 Congresswoman Maloney introduced H.R. 2136: “To amend the Internal Revenue Code of 1986 to provide an exception from certain reporting requirements with respect to the foreign accounts of individuals who live abroad.”

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Potential Consequences For US Expats Of The Trump Tax Plan

Ephraim Moss

The Trump administration has revealed its official tax reform plan. While it’s clear that the plan would make drastic changes to the current U.S. tax system, the brevity of the plan leaves a host of ancillary issues and details either unclarified or unaddressed in the one-page document. This is particularly true for expats – the tax plan gives little insight into whether changes will be sought by the administration that specifically address U.S. expat concerns.

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Corporate Tax Executive Compensation – TaxConnections

Kat Jennings

The retention of highly skilled tax professionals is an important goal for every corporation. The cost of turnover in a tax organization is especially high given the time it takes to train and assimilate a tax professional into a company’s processes, procedures and culture.

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A Holiday Gift: What To Do About The Unfiled FBAR – Part 2

John Richardson

Yesterday, we started this blog post to hopefully encourage those with U.S. tax issues to consider whether they can deal with minor/unintentional FBAR violations as a “stand alone single problem”. There may be no need to escalate and expand one single problem into a multi-dimensional full blown tax problem that may end up with unintended and unanticipated costly professional fees as well as undue time spent! Read on and learn why. Keeping a calm head is most important, even if it is most difficult to do in the face of the scary situation of not being in compliance with the U.S. tax and regulatory regime.

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Canada-US Cross-Border Tax Issues When Winding-Up a Subsidiary

Canadian corporations form US Subsidiaries, and US Corporations form Canadian Subsidiaries, all the time.

What are the cross-border tax implications when those subsidiaries are wound-up? This article will provide an overview of those implications.

Winding-up a US Subsidiary (“USco”) of a Canadian Corporation (“Canco”)

For US tax purposes, proceeds received on the wind-up of USco are generally not treated as a dividend, and hence no U.S. withholding tax should apply.

Rather, such amounts would generally represent proceeds from the shares which should Read more

The Commerce Clause – Due Process and Cross Border Taxation

Introduction

Cross border taxation risks of international enterprise incorporates two basic themes, one of which is the interpretation of the United States Commerce Clause and the Due Process distinction from jurisdictional analysis. It is one of the two basic aspects that govern the authority of a source and resident country or state to tax international commerce.

In the electronic commerce world the courts have embraced an evolution of Due Process requisite of jurisdiction and of commerce. That analysis for both turns upon the judicial case law evolution that focuses on the contact with the state or country that imposes taxation from their border. Read more

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