US clients with international tax issues: Five helpful tips
U.S. persons (citizens and permanent residents) whose financial matters extend overseas may face a tax situation that virtually no other country’s nationals do.
Tax Planning; Tax Minimization
PFIC considerations for non-US SPACs
As SPAC activity has increased, non-U.S.-domiciled SPACs have become more prevalent and carry major U.S. tax-compliance ramifications due to their potential treatment as a PFIC for U.S. investors.
Court says statutory language precludes substance-over-form analysis
The plain language of the statute allowed taxpayers to shelter income from all tax using a foreign sales corporation and Roth IRAs.
Transfer price adjustments don’t necessarily increase import duty costs
Importers should consider transfer-pricing arrangements in advance, based on the totality of the circumstances, to assess any potential refund of duties on adjusted prices to imported goods.
Unintended consequences of foreign branch reporting
Certain U.S. citizens and U.S. residents doing business abroad can have surprising tax reporting obligations as a consequence of the IRS's revised instructions to Form 8858.
Transfer pricing and sales/use tax
This discussion outlines the basics of sales and use tax and transfer pricing, considers how intercompany transfer pricing may unintentionally lead to sales tax exposure, and offers steps to avoid audit assessments and penalties.
Buyer’s withholding obligation under FIRPTA
This article discusses some details of the Foreign Investment in Real Property Tax Act of 1980.
