Archive: foreign tax

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U.S. Government Contractors and Cross-Border Payroll Tax Issues

The cross-border global expansion of business activities continues to increase exponentially in the U.S. government contracting industry. Many government contracting companies are performing contracts more often in other countries and on a greater scale than ever before. As a result, contractors are being faced with some critical planning opportunities to manage the cross-border flow of […]
June 25, 2019

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. Having been an expat myself, I remember the excitement, anticipation, and anxiety that comes with picking up your life (and that of your family) and moving to a foreign country. In the weeks leading up to […]
December 12, 2017
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  • Aronson

G Election Trues Up Timing to Recognize CFC & PFIC Income for Net Investment Income Tax

The “G” election,  provided for under U.S. Treas. Reg. Section 1.1411-10(g), impacts U.S. direct and indirect individual shareholders of controlled foreign corporations (“CFCs”) and passive foreign investment companies (“PFICs”). A U.S. individual shareholder of a CFC or PFIC with a qualified electing fund (“QEF”) election is required to report and pay U.S. federal tax on […]
October 10, 2014

IRS Issues New Transfer Pricing Audit Roadmap

The IRS released a Transfer Pricing Audit Roadmap on February 18, 2014.  The Roadmap, which was issued through the IRS Transfer Pricing Operations of the Large Business and International (LB&I) division, was developed to provide audit techniques and tools for transfer pricing examinations.  The Roadmap is designed as a comprehensive toolkit based on an audit […]
March 3, 2014

Tax Alert: IRS Issues New Passive Foreign Investment Company Regulations and Revises Form 8621 PFIC Information Return Instructions

On December 30, 2013, the IRS issued Treasury Decision 9650, which includes new temporary regulations under Treas. Reg. Sections 1.1291-1T and 1.1298-1T regarding Passive Foreign Investment Company (“PFIC”) reporting. The new regulations provide guidance on determining ownership of a PFIC and on the annual reporting requirements for shareholders of PFICs. The regulations are effective for […]
February 16, 2014

Net Investment Income Tax Applies to U.S. Shareholders of CFCs and PFICs

The new 3.8% net investment income tax applies to U.S. individual, trust and estate taxpayers for tax years beginning after December 31, 2012. For U.S. individual taxpayers, the tax is 3.8% of the lesser of net investment income or the excess of modified adjusted gross income over a threshold amount. The threshold amount is $250,000 […]
November 15, 2013

Offshore Voluntary Disclosure Program Offers Amnesty for U.S. Taxpayers

The Offshore Voluntary Disclosure Program offers U.S. taxpayers the opportunity to come into compliance with U.S. federal foreign reporting obligations. The current program does not have a filing deadline, but the IRS may close the program at any time. A U.S. individual or company is required to file a Report of Foreign Bank and Financial […]
November 1, 2013

IRS Extends FATCA Implementation Deadline

On March 18, 2010, the Foreign Account Tax Compliance Act (FATCA) was enacted under Sections 1471 through 1474 of the U.S. Internal Revenue Code. If certain due diligence and reporting requirements are not satisfied, FATCA generally imposes a 30% withholding requirement on payments of certain types of U.S. source income to foreign financial institutions (FFIs) […]
August 10, 2013

Offshore Voluntary Disclosure Program Still Open for Quiet Disclosures and Formal Disclosures

In January 2012, the IRS extended the Offshore Voluntary Disclosure Program. The program allows U.S. taxpayers to pay penalties and taxes for prior years in connection with the filing of delinquent U.S. international tax reporting forms. The forms that may be filed in a disclosure include the Form 5471 regarding ownership of a foreign corporation […]
July 22, 2013

International Tax Developments in FY2014 Greenbook

The U.S. Treasury Department released its General Explanations of the Obama Administration’s Fiscal Year 2014 Revenue Proposals on April 10, 2013. The publication, known as the Greenbook, includes the following international tax proposals that would effectuate reform of the U.S. international tax system. (See General Explanations.) 1. Defer Interest Expense Deduction Related to Deferred Income […]
May 15, 2013