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Activities of foreign persons in the United States

Tax issues of foreign persons in the United States...

Posted by The Accounting and Tax on 02/16/2016

Planning for outbound transactions

Planning for outbound transactions...

Posted by The Accounting and Tax on 02/11/2016

International tax tax issue host country taxation issues tax treaties structuring foreign operations low-tax foreign jurisdictions high-tax foreign tax jurisdictions debt financing local tax incentives transfer pricing tax treaties foreign hold

Planning of Foreign Operations

Tax Issues...

Posted by The Accounting and Tax on 02/05/2016

International tax tax issue host country taxation issues tax treaties structuring foreign operations branches subsidiaries branch versus subsidiaries advantages of subsidiaries hybrid entities reverse hybrid entities information reporting for p

Sale of Export Property

Sale of Export Property...

Posted by The Accounting and Tax on 02/03/2016

International tax Export Export Property IC-DISC Destination test IC-DISC benefit IC-DISC income Domestic production deduction sale of export property manufacturing requirements the destination test.

Interest charge domestic international sales corporations

IC-DISC...

Posted by The Accounting and Tax on 01/31/2016

International tax interest charge domestic international sales corporation IC-DISC taxation of IC-DISC form 8404 gross receipts test export asset test accounts receivable temporary investments export property loans.

Rules for foreign currency transactions

Rules for determination of amount, timing, character and source of foreign currency gains and loss are present in code section 988. Following transactions are included in code section...

Posted by The Accounting and Tax on 01/28/2016

International tax foreign currency translations foreign currency transactions debt instruments receivables and payables foreign currency gain or losses tax consequences of currency transactions hedging transactions hedged debt instruments foreign

Foreign Currency Translations and Transactions

Currency translation issues:Foreign branches and subsidiaries keep their books and records in the currency of host country.Parent companies in USA are required to compute their taxable...

Posted by The Accounting and Tax on 01/27/2016

International tax foreign currency translations foreign currency transactions qualified business unit functional currency distributions rules for dividends foreign withholding taxes deemed paid foreign tax credit subpart F inclusion PFIC inclusio

What are Passive Foreign Investment Companies?

Background:U.S investors in foreign mutual funds could avoid U.S taxes. The fund itself could avoid U.S taxes because it was a foreign corporation that only derived foreign source...

Posted by The Accounting and Tax on 01/19/2016

International tax passive foreign investment companies PFIC definition of PFIC Income test asset test QEF taxation of PFIC reporting requirements for PFIC qualified electing fund excess distribution method market-to-market election.

What are anti deferral provisions?

USA will only tax foreign business earnings if it repatriates it to USA through dividends. This policy is known as “deferral”. Deferral creates an opportunity for avoiding...

Posted by The Accounting and Tax on 01/10/2016

International tax anti-deferral provisions controlled foreign corporation Sub-part F income insurance income foreign base company income sales income foreign base company service income foreign base company oil related income principal types of U

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