Archive: international tax

  • Clear Filters

Bureau of Economic Analysis (BEA) Survey of U.S. Foreign Direct Investment Form BE-10 Due May 29, 2020

The U.S. Department of Commerce has launched a benchmark survey through the Bureau of Economic Analysis (BEA) that requires all U.S. persons to report a 10% or greater ownership interest in a foreign business enterprise. The BEA defines a business enterprise as “any organization, association, branch, or venture which exists for profit-making purposes or to […]
April 7, 2020

U.S. Shareholders of Foreign Corporations and the Moving Target of Form 5471

The 2017 Tax Cuts and Jobs Act (TCJA) enacted significant changes to the U.S. international tax regime. U.S. shareholders are affected by the changes that impact the U.S. tax consequences of owning a foreign corporation. The TCJA revised the technical rules applicable to U.S. shareholders of controlled foreign corporations (CFCs). Along with issuing guidance on […]
January 8, 2020

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

Avoid Penalties Related to International Tax Filings

The IRS Large Business and International Process Unit (LB&I) issues internal practice guidance from time to time regarding U.S. international tax requirements. On May 11, 2017, the IRS provided guidance on the Form 5471 penalties in an International Practice Unit (IPU) release. The U.S. federal Form 5471 is a U.S. international information return that discloses […]
December 7, 2017

What Should I Do if I Did Not Report…

Foreign Accounts, Offshore Assets, Ownership of Foreign Companies, Foreign Gifts and Inheritances, or Interests in a Foreign Trust? It is a common misunderstanding that a person with U.S. citizenship or residency believes foreign accounts, foreign sources of income, and foreign assets do not need to be reported on their U.S. federal tax return. A failure […]
February 8, 2017

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 tax returns were focused on foreign partner tax withholding? In 2017, partnerships that file U.S. federal partnership tax returns for the 2016 tax year using Form 1065, must make more extensive international tax reporting disclosures. Here are some items to pay close attention […]
February 2, 2017

Section 338(g) Election for the Acquisition of a Foreign Target Corporation

A Section 338 election has the effect of recharacterizing a taxable stock acquisition as a deemed asset acquisition. The advantage to the buyer is the step up in the basis of the assets deemed acquired to the fair market value on the date of purchase. In the context of a cross-border acquisition, there are some […]
August 21, 2015

Late FBAR or Form 5471? IRS Amnesty for Unreported Foreign Accounts and Offshore Assets

Are you a U.S. taxpayer with foreign accounts or offshore assets? Have you reported all of the income from the foreign accounts or offshore assets on your U.S. federal tax return? Have you filed all required Foreign Bank Account Reports (FBARs) and other foreign reporting information returns, such as the Form 5471 to report ownership […]
July 16, 2015

2014 FinCEN Form 114: Foreign Bank Account Reports Due June 30, 2015

The U.S. Financial Crimes Enforcement Network (FinCEN) Form 114 is the Report of Foreign Bank and Financial Accounts. The FinCEN Form 114 is commonly referred to as the “FBAR,” which replaces the prior Form TD F 90-22.1. A U.S. person must file an FBAR if the U.S. person has a financial interest in or signature […]
May 21, 2015