When tax reform was passed last December, the new legislation included a requirement for certain individuals with an interest in a foreign corporation to calculate and report a Repatriation Tax on their 2017 tax returns. This tax (or the initial installment payment) was due [...]
If you are an individual who owns or holds at least a 10% interest in a Controlled Foreign Corporation (CFC), you have probably spent the last 4 to 6 weeks working your CPA on how to calculate the new Repatriation Tax[1] under the Internal [...]
The IRS released Frequently Asked Questions for the Repatriation Tax on March 13, 2018. Under FAQ 11, the IRS politely asked all individuals who have a repatriation tax issue not to electronically file Form 1040 until April 2, 2018. Well, here we are, and [...]
Many of our clients are self-employed consultants who perform their consulting services both in and outside the United States. Many of these clients have asked us how the new tax reform law might affect them. Specifically, they are inquiring about whether they qualify for [...]
The Tax Cuts and Jobs Act of 2017 ushered in a host of tax provisions you may have heard of, including the Repatriation Tax,[1] GILTI,[2] and Base Erosion[3] taxes. But, there are some little-known changes that may make a big difference on the 2017 [...]
With recent tax reform dominating the news, many nonresident alien taxpayers may be unaware that other, older legislation has resulted in additional reporting requirements on their 2017 tax returns (and that failure to meet these requirements may result in steep penalties, of course). As [...]
Do you have a 10% or more interest in a foreign corporation? If so, then you may have a repatriation tax issue on your 2017 (not 2018!) tax return. Although the new tax legislation signed into law by President Trump on December 22, 2017, [...]
Do you have a 10% or more interest in a foreign corporation? If so, then you may have a repatriation tax issue on your 2017 (not 2018!) tax return. Under the new tax legislation, the United States is shifting international corporate taxation from worldwide [...]
On August 14, 2017, TWG International Tax Director Mishkin Santa interviewed UK advisor Mark Summers on hot topics in U.S.-UK taxation. In the first part of this two-part series, Summers addresses common tax planning considerations. What are some common tax planning strategies for U.S. [...]
Let me start with a brief story: A friend of a friend once told another friend that he could eliminate U.S. tax on his business profits if he set up a company in a “tax haven” and never brought money back to the U.S. [...]
