Breakdown: Foreign Business Interest Expense Limitation Final Regulations
Significant final regulations under section 163(j), which includes the interest expense limitation that was issued in July 2020 to reflect amendments made by the Tax Cuts and Jobs Act (TJCA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act, were recently signed at the beginning of January 2021. There
How Transfer Pricing Can Make or Break your Tax Strategy
For multinational businesses, there is perhaps no greater source of confusion and frustration in the tax arena than transfer pricing. Transfer pricing is the arm’s length price charged for good and services between related parties. In cross- border transactions, establishing the correct transfer price is particularly critical because each country
How’s Biden’s Tax Plan Could Impact International Companies
President-Elect Joe Biden has spoken about implementing a lot of potential tax changes while on his campaign trail for president in 2020. While most of the changes he has discussed are in the individual tax realm, but he has a few international corporate tax changes that could affect U.S. corporations
International Reporting – Are You In Compliance?
U.S. Taxpayers, including individuals, companies, trusts, and estates that have delinquent, incomplete or late-filed foreign information returns have significant penalty exposure. Forms 5471, 8865, or 8858 may need to be filed if the U.S. taxpayer has a direct or indirect interest in a foreign corporation, foreign partnership, or foreign disregarded
The Ins and Outs of Cross-Border Taxation
Understanding Outbound Transactions Cross-border taxation can be divided into various categories based on the type of the transaction, with the highest division being “Inbound vs. Outbound.” Inbound refers to non-U.S. persons (and in this case, “persons” meaning both individuals as well as entities) having U.S. income. Outbound is the opposite,
New Rules to Take Deduction on Foreign Income
Proposed regulations on Foreign Derived Intangible Income (FDII) were released earlier in 2019. One of the main highlights to these proposed regulations was the new strict documentation rules. For a brief recap on the release, and to learn when a C-corporation can benefit from the FDII deduction due to revenue