Many U.S. owners of foreign companies are surprised to hear that the new repatriation tax not only applies to “repatriated” foreign earnings, but also to foreign earnings that are not repatriated into the U.S. They are even more surprised to learn that the deemed repatriation tax may be due as early as the 2018 tax season. While an election is available to pay the net tax liability over eight annual installments, this new tax comes as a surprising frustration to many business owners of foreign companies.» Read More
An “F” reorganization is a type of tax-free reorganization under Internal Revenue Code Section 368(a)(1)(F), which includes a mere change in identity or form of one corporation. F reorganizations are typically used to effectuate a tax-free shift of a single operating company. They are frequently used as part of a pre-sale strategy or for changing certain undesired attributes of an operating company. » Read More
In the 2017 Statistics of Income Bulletin, the IRS reported that foreign recipients of U.S. source income from treaty countries had an average withholding rate of 13.9% compared to 25.6% for payments made to residents of non-treaty countries. Absent certain exceptions and/or exemptions, a foreign person, including a foreign entity, is generally subject to tax at a flat 30% rate on U.S.» Read More
Several tax bills passed by Congress late in 2015 changed the deadlines for filing federal income tax returns for partnerships and most limited liability companies, which are treated as partnerships for tax purposes. Other required filings might be affected as well.
The new rules generally take effect for tax years beginning after December 31, 2015, so that, for calendar year filers, the new deadline applies to 2016 tax returns, which are due in early 2017.» Read More
On October 9 and October 10, the Internal Revenue Service issued new guidance and questions and answers for taxpayers regarding the Streamlined Filing Compliance Procedures announced this summer. For a detailed explanation and link to this guidance please click here.
Taxpayers previously considering the Offshore Voluntary Disclosure Program should also consider whether they may be eligible for this Streamlined Program.» Read More