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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..

TAX EXTENDERS: LOOK-THROUGH RULE FOR CFCs EXTENDED!

December 28, 2020

Although the provision that allows for the deduction for expenses paid with PPP loan proceeds and..

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..

TITLE TRANSFER ON FOREIGN SALES: TIME TO CHANGE BACK TO THE US?

December 8, 2020

It used to be common for US taxpayers to transfer title to product sales destined for a foreign..

TWO NEW INTERNATIONAL TAX COMPLIANCE CAMPAIGNS ADDED TO IRS ACTIVE LIST

December 1, 2020

The IRS Large Business and International (LB&I) Division recently added four new compliance..

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”)..

FINAL REGULATIONS ON SALE OF US PARTNERSHIP BY FOREIGN PARTNER

October 14, 2020

Prior to the enactment of Sec 864(c)(8) as part of the TCJA-2017, a foreign partner could sell an..

COVID PROCEDURES AFFECTING THE FOREIGN EARNED INCOME EXCLUSION

October 7, 2020

In response to the pandemic, the IRS has waived the residency and presence tests that apply for..

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..

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