Tag Archive for International Tax

Foreign Earned Income Exclusion

Foreign Earned Income Exclusion

U.S. citizens and resident aliens who live abroad are taxed on their worldwide income.  But such taxpayers may qualify for the foreign earned income exclusion, which allows certain taxpayers to exclude up to $112,000 (in 2022) of their foreign earnings from income, as well as to exclude or deduct certain foreign housing costs.  Note, however, that not all U.S. expats qualify to take advantage of the foreign earned income exclusion.  In addition, business owners may be subject to other complications and taxpayers residing in countries that have tax treaties with the United States may have certain tax planning opportunities.

The Foreign Earned Income Exclusion: The Basic Requirements

To qualify for the foreign earned income exclusion, the taxpayer must have (i) foreign earned income, (ii) a tax home in a foreign country (the “tax home” test), and (iii) the taxpayer must be one of the following:

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Looming Transfer Pricing Exams & IRS Preparedness Measures (Part 3 of Series): “TPEP Execution Phase”

Doug Schwerdt

In this third article in our Looming Transfer Pricing Exams & IRS Preparedness Measures series, we highlight and summarize the essential aspects of the IRS’s Transfer Pricing Examination Process (TPEP) Execution Phase.

The Execution Phase immediately follows the opening conference and consists of continued risk assessment, fact finding, information gathering, and issue development. Stages of issue development include determining the facts, applying the law to those facts, and understanding the various tax implications of the issue. The issue team is advised to make every effort to resolve factual differences with the taxpayer.

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Written by | Posted in Internal Revenue Service • TPEP • Transfer Pricing • Transfer Pricing Examination Process • Transfer Pricing Guidance • WTP Advisors

Looming Transfer Pricing Exams & IRS Preparedness Measures (Part 2 of Series): “TPEP Planning Phase”

GUY SANSCHAGRIN

In this second article in our Looming Transfer Pricing Exams & IRS Preparedness Measures series, we highlight and summarize the essential aspects of the IRS’s Transfer Pricing Examination Process (TPEP) Planning Phase.

The Planning Phase determines the scope and issues of the transfer pricing examination. The TPEP states, “Issues selected for examination should have the broadest impact on achieving compliance regardless of the size or type of entity.” Important steps in the Planning Phase are: 1) the Initial Transfer Pricing Risk Assessment, 2) issuance of the Initial Transfer Pricing Information Document Request (IDR), 3) IRS internal planning meetings, 4) development of the exam plan, timelines and milestones, and 5) the opening conference, which is the final step of the Planning Phase and marks the transition to the Execution Phase.

Evolving Guidance
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Senior Tax Manager – International (Milpitas, California)

Senior Tax Manager Of International

TaxConnections has been retained to conduct a search for a Senior Tax Manager, International for a publicly listed company in the San Jose, CA area. Our client seeks a Senior Tax Manager who will report to the VP Tax and assist on a wide range of international tax responsibilities. Your willingness to expand your tax knowledge is key in this role. International experience with multinational operations in Asia and Germany very helpful.

Primary Responsibilities

This role requires an individual with the willingness to assist and take responsibility for a variety of interesting international tax projects as required or needed to include:

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Senior Tax Manager/ International Tax  (Rutherford, New Jersey)

Position is responsible for providing technical tax leadership, with an emphasis on international tax. Position is responsible for international tax matters for the Americas consolidated group including preparation and/or review of international portions of the consolidated tax provision, preparation and/or review of international reporting requirements for the US consolidated return and transfer pricing. Transfer pricing responsibilities include managing documentation processes, preparation and review of various analyses, providing guidance to Brand Finance and Operations teams and intensive interaction with HQ transfer pricing team. Responsible for transfer pricing in a complex inbound, multinational group. Position is responsible for ensuring timely compliance and reporting by the international affiliates in the group for both income and transaction taxes. Highly visible position especially regarding transfer pricing. Significant interaction with the business as well as accounting teams.

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Governments Dismantling Harmful Tax Incentives Worldwide: BEPS Project Driving Major Changes To International Tax Rules

Governments have dismantled, or are in the process of amending, nearly 100 preferential tax regimes as part of the OECD/G20 BEPS (Base Erosion & Profit Shifting) standards to improve the international tax framework, according to a progress report released this month.

The report provides details on the outcome of peer reviews undertaken of 164 preferential tax regimes identified amongst the more than 100 jurisdictions participating in the OECD Inclusive Framework on BEPS.

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Written by | Posted in International • Tax Updates

Mamma Mia! Italian Tax Court Rules On Inter-Company Loan Interest Withholding Tax, Beneficial Owner Withholding Exemption

Marco Rossi, Tax Advisor

With its Ruling n. 4091 of June 12, 2017, the Eighth Department of Tax Commission (District Tax Court) of Milan, Italy ruled that upon the cancellation of an inter company loan from a Dutch parent company to its Italian subsidiary, the interest accrued on the loan and deducted by the Italian subsidiary on an accrual basis, during the course of the loan, is deemed “constructively received” by the foreign parent, and is potentially subject to the Italian interest withholding tax (at the rate of 20 percent, pursuant to article 26, paragraph 5 of Presidential Decree n. 600 of 1973, recently increased to 26 percent).

However, the Tax Court also ruled that the Dutch parent company qualified as “beneficial owner” of the interest, and was eligible for the withholding tax exemption granted under article 26-quater of Presidential Decree n. 600 of 1973, which implemented the EU Directive n. 2003/49/CE (so called interest and royalties directive).

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FATCA’S Unintended Consequences – Feeding Corruption And Suppression Of Political Rivals

William Byrnes, Tax Advisor

FATCA’s primary purpose was for the U.S. government to obtain otherwise private financial information and exercise control of the global financial industry. Unlike a conventional withholding tax which actually intends to collect tax, FATCA imposes penalties based upon non-compliance with tax.

The tax revenue projections, which were used to validate the passage of FATCA did not show FATCA raising any significant tax revenue annually. In fact, except for the extraordinary penalties assessed, little additional tax has been collected. In comparison to the annual on budget spending by the U.S. government, the actual amount of tax collected by FATCA is statistically insignificant.

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American Expatriates In London – Tax Info You Need

Hugo Lesser

American expats living in London find themselves in the unenviable position of having to file both U.S. taxes as a U.S. citizen, and UK taxes as a UK resident, on their worldwide income.American expats living in London find themselves in the unenviable position of having to file both U.S. taxes as a U.S. citizen, and UK taxes as a UK resident, on their worldwide income.

To complicate things further, the UK tax year runs from April 6th to April 5th, rather than being the calendar year. Read More

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Canadian Tax FAQs – What Is A Trust Audit?

What is a Trust Audit?

Some professionals such as Real Estate Agents and Lawyers keep trust accounts (funds held on behalf of their clients). There are special accounting rules for these trust accounts and a Trust Audit is designed to ensure compliance with these accounting rules. Read More

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PFIC And Canadian Mutual Funds

Why are PFIC rules important for holders of Canadian mutual fund?

Many American citizens living or working in Canada have invested in Canadian mutual funds – likewise, many Canadians who subsequently moved to the United States retained their Canadian mutual funds holdings. They likely are unaware of the PFIC rules. Consequently many American taxpayers holding Canadian PFIC have not met their reporting obligations. Not only that  but PFIC investments are to be avoided since its taxation (with the exception of the QEF regime) is designed to be punitive. Read More

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Hale Stewart Webinar – U.S. International Tax – Today!

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.

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Written by | Posted in Tax Education
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