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Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Blank Rome LLP

New Mexico Again Loses Unity of Foreign Income

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The New Mexico Taxation & Revenue Department (“Department”) wrongly ignored the statutory exclusion for foreign corporations incorporated in foreign countries that do not engage in a trade or business in the United States...more

International Lawyers Network

Establishing a Business Entity in Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Foodman CPAs & Advisors

¿Está Su Preparador De Impuestos De 2023 Haciendo Las Preguntas Correctas?

La temporada de impuestos está aquí y en el 1/2/24, el IRS le recordó a los contribuyentes que elijan cuidadosamente a su preparador de impuestos de 2023 al preparar sus impuestos de 2023. Los contribuyentes son, en última...more

Foodman CPAs & Advisors

Is Your 2023 Tax Preparer Asking You The Right Questions?

Tax season is here and on 2/1/24, the IRS reminded Taxpayers to choose a 2023 Tax Preparer carefully when preparing their 2023 Taxes. Taxpayers are ultimately legally responsible for all the information on their income tax...more

International Lawyers Network

Establishing A Business Entity In Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Dorsey & Whitney LLP

DSU Plans May Run Afoul of U.S. Deferral Election Timing Rules Resulting in Adverse U.S. Tax Treatment

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A Canadian company adopting a deferred share unit plan (DSU plan) for its directors must consider U.S. tax implications for U.S. taxpayers. It is important to remember that U.S. citizens and U.S. residents for tax purposes...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

International Lawyers Network

Establishing A Business Entity In Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - Limited companies: Corporation and Limited Liability Company - When...more

Freeman Law

[Webinar] Preparing Form 5472 step by step instructions - February 22nd, 12:00 pm - 2:00 pm CT

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You are invited to Freeman Law Tax Academy Series - FORM 5472: STEP BY STEP INSTRUCTIONS - Learning Objectives: - Determine the applicability of Form 5472 - Properly complete Form 5472 - Identify prospective...more

Sullivan & Worcester

The Most Draconian Tax Rule in the World

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In today's blog, we look at the most draconian tax rule in the world and examine whether the rule is valid. In addition, we examine a recent United States Tax Court case where the court upheld this draconian rule against a UK...more

Freeman Law

The Tax Court in Brief - January 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

Freeman Law

Everything That You Need To Know About International Tax Penalties

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International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

Foodman CPAs & Advisors

IRS “BEEFS UP” Section 965 COMPLIANCE For 2017 And 2018 Returns

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On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more

McDermott Will & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Foodman CPAs & Advisors

IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations

IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return.  On April 16, 2019, IRS announced the...more

Clark Hill PLC

IRS Approves Three New Enforcement Campaigns Based on Data Analysis and Employee Feedback

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The IRS has announced three focused enforcement areas, all related to international tax compliance. The three campaigns were identified through data analysis and suggestions from IRS employees, highlighting the IRS’s use of...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

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Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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