IRS international inflation adjustments for 2019

The IRS released Rev. Proc. 2018-57 to provide certain international inflation adjustments for 2019. Here is a summary of the adjustments relating to international areas of tax, including the prior year for comparison. Please consult your Henry+Horne tax professional for questions or assistance with your international tax needs. This information is general and should not …

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Tax reform: deducting foreign real estate taxes

One notable change from The Tax Cuts and Jobs Act of 2017 (TCJA) was the limitation of the state and local tax deduction on Schedule A. For those itemizing deductions, the maximum deduction allowed is capped at $10,000 per year, effective on your 2018 tax return. This includes taxes such as real estate tax, personal …

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Foreign partner withholding: a new code section

For most of my career, I have helped clients with domestic business and personal tax issues. The way I saw it, the United States tax code as it relates to these taxpayers was complicated enough – why muddy the waters further by stepping into the world of international taxation? Well, life isn’t always that easy. …

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Proposed regulations for foreign tax credits

The Tax Cuts and Jobs Act (TCJA) changed many facets in the tax world, including the international tax arena. With the changes to how foreign activities are taxed through the onset of global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII), claiming the foreign tax credit became more complex. Taxpayers trying to navigate through …

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Does your partnership have a foreign partner?

If you have a foreign partner in your partnership, you may need to pay a withholding tax on that partner. A partnership that has income effectively connected with a U.S. trade or business is required to pay a withholding tax on the effectively connected taxable income that is allocable to its foreign partners. A foreign …

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So, I left for a wedding in France…

You know that saying “the grass isn’t always greener on the other side”? Debra Callicutt, our International Tax Partner, and I were talking before she left for a recent wedding in France. First, she was stressed about leaving because she has so many Forms 5471 to review before the September 15 tax deadline. But, goodness, …

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Digital tax coming to a tech company near you… possibly

Take a second and look up from your phone. What do you see?… If I had to guess, it would be other people looking down at their phones. If that doesn’t scream digital economy, I don’t know what does. The global market is growing and becoming more and more complex. Companies are reaching out and …

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Transition tax penalty relief, Section 965 update

In a new press release on June 4, 2018, the IRS announced its decision to provide penalty relief to certain taxpayers who were delinquent in making a tax payment for the new transition tax. Section 965 of the code, also known as the transition tax, is a one-time tax on the accumulated earnings held in …

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If you’re not feeling GILTI, you may be soon enough

Have you felt “GILTI” about deferring taxes in your International investment or business?… Probably not, because that may have been one of the many reasons you set up that international company. If you’re not feeling GILTI about it (which you shouldn’t), you may be feeling it, in a financial way, come 2018 tax time! “GILTI” …

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Royal wedding = royal tax pain, international tax issues

My morning routine typically includes tuning into the Dan Patrick show because it’s a sports talk show and I’m a huge sports fan. I was especially excited to tune in this morning as the Phoenix Suns won the NBA Lottery and will select first in the June draft. In addition to sports, Dan Patrick will …

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