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New Form 5472 Filing Requirement for U.S. Disregarded Entities Owned by a Foreign Person
On December 13, 2016, the IRS issued new regulations (T.D. 9796) that requires U.S. disregarded... more
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New Controlled Foreign Corporation Constructive Ownership Rule
The Tax Cuts and Jobs Act enacted in December 2017 changed a constructive ownership rule that... more
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A U.S. Owner of a Foreign Corporation May Need to Report the U.S. Repatriation Tax on the 2017 U.S. Federal Income Tax Return
There was new U.S. international tax legislation enacted in the Tax Cuts and Jobs Act in December... more
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U.S. Tax on a Foreign Person’s Gain from the Sale of a U.S. Partnership Interest
There is a provision in the new U.S. tax legislation that applies to a foreign person’s sale of a... more
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Key U.S. International Tax Provisions in the New Tax Legislation
The new U.S. Federal tax legislation includes some important revisions to the U.S. international... more
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New U.S. International Tax Rules
The new U.S. Federal tax legislation includes some important revisions to the U.S. international... more
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Moving Overseas? Three Tax Tips for U.S. Expatriates
Emigration tax is a tax on expatriates, or those who ceases to be a tax resident in that country.... more
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Avoid Penalties Related to International Tax Filings
The IRS Large Business and International Process Unit (LB&I) issues internal practice guidance... more
Blog
New Form 5472 Filing Requirement for U.S. Disregarded Entities Owned by a Foreign Person
On December 13, 2016, the IRS issued T.D. 9796, new regulations that require U.S. disregarded... more
Blog
What Should I Do if I Did Not Report…
Foreign Accounts, Offshore Assets, Ownership of Foreign Companies, Foreign Gifts and Inheritances,... more
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New U.S. International Tax Reporting Disclosures Required on 2016 U.S. Federal Form 1065 Partnership Tax Return
Remember when international reporting disclosures required on U.S. Federal Form 1065 partnership... more
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Caution: Corporations with NOLs and a Foreign Subsidiary Must File Federal Tax Returns with Form 5471 on Time to Avoid Penalties
Avoid this common misunderstanding. U.S. corporate leaders may assume that their U.S. federal Form... more