U.S. tax and reporting for foreign companies and investments, including Form 5471, GILTI, PFICs and entity classification.
Last week, we started our review of the newly-enacted Tax Cuts and Jobs Act (“TCJA”), focusing on the personal taxation provisions. This week, we focus on the business taxation provisions that we…
Read MoreA common misconception we find in our practice is the belief that the classification of a foreign (non-US) entity is necessarily the same under both the foreign country’s laws and under U.S. tax law.…
Read MoreOne of the major economic fallouts of last year’s Brexit referendum was the sudden and significant depreciation of the British pound. Over the past week, the pound fell sharply again following the…
Read MoreThe IRS recently finalized regulations, previously in proposed and temporary form, which provide guidance on determining the ownership of a passive foreign investment company (PFIC) and the reporting…
Read MoreRecently, the IRS announced that it will focus its audit efforts this year on 13 particular compliance issues, which touch on large business and international activities. This issue-focused effort…
Read MoreIn a new decision, the Tax Court upheld heavy penalties imposed by the IRS on a U.S. expat taxpayer who failed to report his ownership in two foreign corporations. The decision certainly serves as a…
Read MoreIf you are a U.S. expat that has invested or is considering investing in foreign mutual funds, there are a number of serious U.S. tax considerations that you should take into account. These…
Read MoreAre you a U.S. citizen that conducts business overseas through one or more domestic entities, such as a U.S. corporation or partnership? If so, you (or more specifically, the entities that you own)…
Read MoreIt’s hard to believe, but once again we’re approaching that infamous time of the year when we all start to think about our U.S. taxes and pull together the energy needed to put this often complicated…
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