How Many Pages? Additional International Reporting Requirements for Pass-Through Entities
International reporting for pass-through entities has been inconsistent in the wake of the Tax Cuts and Jobs Act (TCJA), and that’s caused problems for owners – and for the IRS. Information for owners has been left as footnotes on the K-1, which is used to report the income, losses, and
How Foreign and U.S. Investors Can Mitigate the Costly Tax on the Sale of U.S. Real Estate
Generally, sellers of U.S. real estate are subject to U.S. taxation on capital gains arising from the sale of the real property. However, under the Foreign Investment in Real Property Tax Act (FIRPTA), the tax cost could be substantially higher. FIRPTA imposes a 10% withholding tax on the transfer (by
Tax Increases on the Horizon for International Operations
Corporations and businesses with international operations may soon see a bigger tax bill. On March 31, 2021, President Joe Biden unveiled the American Jobs Plan, which focuses on upgrading and repairing physical infrastructure, investing in manufacturing, and expanding long-term healthcare services. And to offset the cost of the
Brexit | Has the Drama Finally Subsided?
The United Kingdom (UK) officially left the European Union (EU) on January 31, 2020, in the midst of an extended period of confusion, back-and-forth negotiations and unanswered questions for many businesses and individuals that work and live in the area. With an 11-month transition plan that ended on December 31,
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