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Corporate Taxation

  • Investments by U.S. Investors in Non-U.S. Businesses – Tax Planning and Effective Structuring

    By:
    Gerard O’Beirne, CPA, and Harold Adrion, JD, LLM
    |
    Jun 1, 2017
    Planning and effective structuring for U.S. investors investing in non-U.S. businesses can only be accomplished with an understanding of the various rules that impact cross-border transactions. 

  • Partnership Examinations After the Bipartisan Budget Act of 2015

    By:
    Dean L. Surkin, JD, LLM
    |
    Mar 1, 2017

    The playing field for partnership examinations changes next year, along with how the IRS collects tax on adjustments to partnership income. The partnership—rather than the partners—will pay the tax in the first instance. 

  • Major New Reporting Requirements for Foreign-Owned Single-Member LLCs

    By:
    Lisa S. Goldman, CPA
    |
    Mar 1, 2017
    The Treasury Department has clamped down on a key reporting exemption that foreign-owned, single-member limited liability companies (LLCs) previously enjoyed, significantly impacting any foreign person or entity with holdings in U.S. single-member LLCs that are disregarded for federal income tax purposes. 

  • Taxpayer Advocate Service: A Resource for Tax Professionals

    By:
    Kim E. Randle, Acting Local Taxpayer Advocate (LTA)
    |
    Jan 1, 2017

    The IRS's Taxpayer Advocate Service (TAS) can help you help your clients. If your client is having a tax problem that you haven’t been able to resolve on your own, our advocates may be able to help. Your client may be eligible for our help if his or her IRS problem is causing financial difficulty, or if you believe an IRS procedure just isn't working as it should.

  • Number of Expatriations Continue to Rise

    By:
    Alicea Castellanos, CPA, TEP, N.P. and Jack R. Brister, TEP
    |
    Sep 1, 2016
    American expats continue to renounce their citizenship at an increasing rate, although the overall percentage taking this step remains relatively small. Driving this trend is the fact that the United States is the sole country in the Organisation for Economic Co-operation and Development (OECD) that imposes taxes on its citizens regardless of where they reside. 

  • U.S. Announces Greater Scrutiny of Foreign-Owned LLCs: Is Peer Pressure a Motivator?

    By:
    Alicea Castellanos, CPA, TEP, N.P. and Jack R. Brister, TEP
    |
    Aug 1, 2016

    The United States and other jurisdictions have spent a decade trying to identify owners of foreign corporations. Now, a five-year-old report by the Organization for Economic Cooperation and Development (OECD) might have served as an impetus for a U.S. proposal regarding disclosure requirements for limited liability companies (LLCs). 

  • Form 926: Return by a U.S. Transferor of Property to a Foreign Corporation

    By:
    Mitchell Sorkin, CPA, MBA, PFS
    |
    Aug 1, 2016

    This article is the first in a series of articles explaining various IRS forms that relate to the reporting of foreign transactions.
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