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James J. Miesowicz, CPA

Worldwide Interest Allocation for Foreign Tax Purposes Nixed as Part of American Rescue Plan Act of 2021.

March 8, 2021

If a tree falls in the forest and no one is around to hear it, does it actually make a sound?..

Brutal Results for Foreign Corporation That Failed to File US Tax Returns

March 2, 2021

US Tax Court disallows all deductions for UK company operating in the US on the Outer Continental..

How Are COVID-19 and a PFIC Similar?  Nobody Wants Either One!

February 2, 2021

If you have invested in any foreign corporations, you may be aware that you want to avoid having..

MOVE OVER FBAR REPORTING: FinCEN WANTS US COMPANIES TO REPORT ON THE BENEFICIAL OWNERSHIP OF US COMPANIES!

December 11, 2020

US companies may already be familiar with the requirements to report ownership of foreign bank..

FINAL DOWNWARD ATTRIBUTION OWNERSHIP REGULATIONS DID NOT ELIMINATE “THE MISTAKE”

October 20, 2020

Most international tax professionals and the IRS believe Congress made a mistake (“The Mistake”)..

YEAR-END TAX PLANNING FOR NONRESIDENT ALIENS AND FOREIGN CORPORATIONS “STUCK” IN THE US DUE TO COVID

October 6, 2020

The IRS provided relief to nonresident aliens and foreign corporations affected by the novel..

IMPACT OF RULE CHANGES FOR US SHAREHOLDERS ON DEEMED DISTRIBUTIONS FROM CFCs

July 29, 2020

Recent changes may eliminate some of the deemed distributions from controlled foreign corporations..

FINAL DEBT/EQUITY RULES ON DISTRIBUTIONS: NO CHANGES; STILL CONCERNS

June 2, 2020

The IRS has had a long-standing concern about taxpayers who try to use debt rather than stock..

COVID-19 Tax Relief Measures Require Financial Statement Adjustments

May 12, 2020

The Coronavirus Aid, Relief, and Economic Security (CARES) Act, signed into law on March 27, 2020,..

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