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Foreign Persons doing Business in the United States

Foreign Persons doing Business in the United States

Foreign Persons doing Business in the United States...

Posted by The Accounting and Tax on 03/27/2016

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
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Planning for outbound transactions

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
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Planning of Foreign Operations

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
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How to plan for dividend repatriation?

How to plan for dividend repatriation?

A general rule for tax planning for dividend repatriation includes cross-crediting, minimizing foreign withholding taxes and considering alternative methods of repatriating earnings. Cross-Crediting If...

Posted by The Accounting and Tax on 01/06/2016

International tax foreign tax credit deemed paid foreign tax credit dividends foreign operations cross-crediting residual tax look through rules repatriation of earnings alternative to dividend repatriation minimizing foreign withholding taxes a
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Who can claim a deemed paid tax credit?

Who can claim a deemed paid tax credit?

Who can claim a deemed paid tax credit?   -       A domestic “C” corporation that owns 10% or more of the voting stock and receives...

Posted by The Accounting and Tax on 01/02/2016

International tax foreign tax credit deemed paid foreign tax credit dividends foreign operations computing deemed paid foreign tax credits pooling rule foreign income taxes last in first out approach pooling method earnings and profits distribut
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Computing the deemed paid foreign tax credit

Computing the deemed paid foreign tax credit

Who can claim a deemed paid tax credit?   -       A domestic “C” corporation that owns 10% or more of the voting stock and receives...

Posted by The Accounting and Tax on 12/28/2015

International tax foreign tax credit deemed paid foreign tax credit dividends foreign operations computing deemed paid foreign tax credits pooling rule foreign income taxes last in first out approach pooling method earnings and profits distribut
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