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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New EU general data protection regulation

You may be thinking that there is no point in reading further as your business in located in the United States, not the EU – not true. United States businesses with clients or customers in Europe will be required to comply with these new data regulations, seek guidance on how to implement them and will …

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IRS urges travelers requiring passports to pay back taxes

The IRS strongly encourages taxpayers who are seriously behind on their taxes to pay what they owe or enter into a payment agreement with the IRS to avoid putting their passports in jeopardy. This IRS has begun implementation of new procedures affecting individuals with “seriously delinquent tax debts.” These new procedures implement provisions of the …

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Deemed repatriation from foreign corporations

When it comes to tax reform, most individuals aren’t worried because they have most of the year to plan (at least get an idea of what they may owe in 2019), but that is not true. The Tax Cuts and Jobs Act (“TCJA”) mostly affects tax years starting after 12-31-2017; HOWEVER, there is a small …

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New U.S. territorial tax system – tax reform impact

One of the major changes under the Tax Cuts and Jobs Act is the shift to a more territorial tax system. While most of the world is already on a territorial tax system, the United States has been doing its own thing taxing U.S. corporations on their worldwide income. Under the previous law, the U.S. …

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