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Tag Archive for international tax

FATCA: How Does The Meadows Bill Interact?

John Richardson

(This is a continuation of a previous post by John Richardson titled, “Introducing FATCA – What Does It Mean In Your Life?” It gives a great summary of FATCA and leads directly into this article.)

First, About the FATCA legislation …

2012 – The world according to FATCA – For the compliance industry: “The Gift That Just Keeps on Giving.”

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Webinars—International Tax/Captive Insurance—Register Now

Hale Stewart

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.

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Upcoming Webinars—International Tax/Captive Insurance

Hale Stewart

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.

Read more

Garlock: How Not To Structure A Controlled Foreign Corporation

Hale Stewart

A CFC is a foreign corporation where a U.S. shareholder owns “more than” 50% of the offshore company. Practitioners quickly noted the 50% ownership requirement and correctly deduced that, if a non-U.S. shareholder owned the remaining 50%, the foreign corporation could escape being a CFC.

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Last Opportunity To Register- May 12th 2016 Complimentary Webinar On PFIC- One CE Credit Earned

mary-beth

We only have a limited number of seats left in this free webinar! You will benefit from joining us on Thursday, May 12th 2016 at 1:00PM EDT/10:00AM PDT. If you have ever encountered the IRS Form 8621, you must join us to learn how you will cut away more Read more

Is This Canadian Baby An American Tax Cheat?

Is This Canadian Baby An American Tax Cheat?

A Canadian baby is learning about taxes, banking and activism at a tender age. The eight month old girl received a “Dear Valued Customer” letter from her Canadian bank when she was six months old advising her that her account information may be provided to Canada Revenue Agency to pass on to IRS.  The wee “Valued Customer” was directed to complete, sign and mail forms to the bank.

Baby Elle (not her real name) and her Canadian parents were Read more

Top 25 International Tax Questions

John Dundon

Please feel welcome in the USA. Fear NOT the paper tiger that is the US Tax Code or the rhetoric of pantywaist politicians! Much of maintaining compliance with the US Tax Code distills down to understanding among other things these 3 simple concepts:

1.The tax obligations of your current visa

2.What country you are effectively connected

3.Whether you meet the substantial presence test in the USA Read more

International Tax – Traps For The Unwary

Introducing Tax Expert Doug Eckert, Tax Partner, Brown, Smith, Wallace, St. Louis, Missouri

 

Doug will be presenting at TaxConnections Internet Tax Summit and discussing the repatriation of funds without paying double taxation and various techniques you will want to know about.  His presentation begins Tuesday, September 22nd at 10:00AM (PST).

Gather your tax department for this informative session with Doug Eckert.

(See Video Introduction Below) Read more

BEPS And Planet Mars

NASA recently announced that your name can be put on the planet Mars. This is incredibly great news for the people with good fortunes who are thrilled by the opportunity to gain their foothold in the universe and enhance their fame. However, in another space mission, scientists are attempting to find out if any life exists in other planets.

Think about it. If they indeed were able to find the life on Mars and if the inhabitants there happen to be much more advanced than the humans on earth, they are likely to have a tax law that can tax such inbound activities. Beware and think before you make that tempting decision.

Putting your name on a planet may have its other side. If “cross planet” law applies and Read more

U.S. Law Firms Consulting In India – Trap For The Unwary

International legal and independent professionals consulting in India often have issues receiving funds from their clients in India. India has stringent exchange control regulations contained in the Act called Foreign Exchange Management Act – FEMA. Accordingly all foreign remittances must go through certain procedures. Additionally, Income Tax Department asks for “Tax Residency Certificate” (TRC) from the US service provider so that the treaty benefits can be allowed. If TRC is not produced, the payer must withhold tax from the income remitted to US service provider. This is true regardless of where the services were provided.

Until recently, it was mandatory that TRC issued by foreign tax authority must contain all items required by the government of India in order to exempt any tax withholding Read more

Section 482 Enforcement – Primary and Correlative Adjustments

Introduction

In making use of Offshore Financial Centers taxpayers will invariably have a structure of entities that are related taxpayers by virtue of common ownership. Because these related taxpayers engage in transactions among themselves, they present opportunities to shift items of income, deductions, and credits through the process of allocations in accounting for deductible items and income. (See TaxConnections, Introduction to Section 482 and International Financial Centers, April 24, 2014) These types of transactions between related parties are to be regulated to prevent what may be perceived to be abuse and avoidance of tax; Section 482 of the Code is designed to implement that regulation. Read more

Understanding The PFIC Rules Without Suffering A Migraine

The PFIC regime was not introduced until 1986. Prior to 1986, U.S. taxation of foreign corporations was strictly tied to control of the corporation held by U.S. persons. This allowed not only the foreign mutual fund to avoid U.S. taxation, but also U.S. persons who invested in the fund. How so?

For starters, the fund itself avoided U.S. taxation because it was a foreign corporation that derived only foreign-source income. The fund was able to avoid the taint of being classified as a controlled foreign corporation, or “CFC” because it was owned by a large number of U.S. and foreign investors, each of whom owned a relatively small percentage.

U.S. investors avoided U.S. taxation in two primary ways. First, the fund paid no dividends. Read more

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