Foreign Tax Credits Clarified in Proposed Regulations
In December of 2017, the Tax Cuts and Jobs Act (“TCJA”) brought sweeping tax reform to the U.S. The U.S. moved from a worldwide tax system to a partial territorial tax system. The TCJA significantly changed the way the U.S. taxes foreign activities for businesses and individuals. New provisions, including
What Do the Steel and Aluminum Tariffs Mean to Manufacturing?
Production and jobs are on the line after the tariffs on steel and aluminum were announced by President Trump earlier this year. In the short term, the American Steel and Aluminum manufacturers are benefiting as the price for steel has rose upwards of 60%, but ultimately the increased demand has
Big Penalties For Missing This Easy-To-Overlook Foreign Reporting
Every five years, the Bureau of Economic Analysis (BEA), part of the US Department of Commerce, issues a mandatory survey that must be filed by US Persons engaged in certain foreign activity. The last survey was required five years ago, and it is due again in 2018. There is no
The Upside to Enterprise Risk Management
Large manufacturing and distribution companies have been using enterprise risk management for many years. Only recently, however, have smaller manufacturers and distributors begun considering ERM to reap its many rewards. ERM involves identifying, assessing, quantifying and addressing all types of risks across the company – operational, human, financial, market and
6th Circuit Upholds Tax Avoidance: IC-DISC as Vehicle for Roth IRA Investment
In a recent, well-reasoned case, the Sixth Circuit upheld a taxpayer’s use of an IC-DISC as a Roth IRA investment to accumulate earnings tax-free. The investment was established by the following steps: Roth IRA owns shares of Holding Company (Holdco); Holdco owns shares in IC-DISC, a tax-exempt entity for export
Transfer Pricing Compliance Issues Targeted in new IRS Campaign
The IRS has launched an initiative under the Large Business and International (LB&I) Division to audit U. S. subsidiaries of foreign multinational corporations which operated as distributors in the US for product manufactured by the related party for sale to U.S. customers. The LB&I published a Practice Transaction Unit in