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
Payroll Implications of the CARES Act for Manufacturers
Estimated at over $2.2 trillion, the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 is the single most expensive legislation in U.S. history. The CARES act was implemented rather quickly when it was signed into law by President Trump in March of 2020. It was intended to provide
FDII Regulations – Another Win for the Taxpayers?
The final IRC Section 250 regulations were released on July 9, 2020. Section 250 provides deductions for Global Intangible Low-Taxed Income (“GILTI”) and Foreign-Derived Intangible Income (FDII). The final regulations are viewed as taxpayer-favorable as they reduced some documentation requirements and provided more flexibility to substantiate the deductions. In 2017,
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,
The GILTI Verdict Is In
Retroactive and Future High-Tax Exceptions Available New regulations released by the Treasury Department on July 21, 2020 have confirmed inclusion of a high-tax exception to avoid global intangible low-taxed income (GILTI). Released under IRC Section 951A and the temporary regulations under section 954, these regulations have been anxiously awaited since