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Entries by Ryan Miller, Katherine Malarsky

New GILTI Rules Target U.S. Shareholders of Controlled Foreign Corporations

Posted 2:30 PM by
As a general rule, the earnings of a foreign corporation are not subject to U.S. taxation until such earnings are distributed as dividends. The Subpart F rules have long been in place to subject the earnings of a controlled foreign corporation (CFC) to U.S. taxation whether or not such earnings are actually distributed. The tax reform legislation passed in Dec. 2017 imposed an additional anti-deferral rule referred to as GILTI (Global Intangible Low-Taxed Income). The new GILTI inclusion rules function in a manner similar to the existing Subpart F regime.
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Litigation Activity Keeps Spotlight on Reporting of Foreign Financial Accounts

Posted 12:00 PM by
With penalties including monetary fines and possible jail time, the Internal Revenue Service (IRS) and Department of the Treasury have shown how seriously they treat violations related to foreign financial account reporting. Considering such tough penalties, it is critical to understand who is required to file, what information is needed, and how recent cases could impact you.
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New Guidance for Complying with Code Section 965 – Deemed Repatriation

Posted 4:00 AM by
The IRS has released guidance related to Code Section 965 which was added by the Tax Cuts and Jobs Act of 2017 (TCJA). Code Section 965 imposes a transition tax that calendar year taxpayers must pay with their 2017 tax returns if they have investments in certain specified foreign corporations. The guidance is provided via Frequently Asked Questions (FAQ) posted to the IRS website.
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2017 Tax Reform: Key International Tax Provisions

Posted 4:19 PM by
The tax reform bill (“Tax Cuts and Jobs Act”) has now been passed by both houses of Congress and is expected to be signed into law by President Trump in the coming days. Below is a look at the final provisions relating to concepts of international taxation, including a summary of the most significant and broadly applicable changes.
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Section 987 Regulations: Implementation Delay

Posted 5:00 AM by
The Internal Revenue Service (IRS) recently announced in Notice 2017-57 that it will defer the effective date of the final Treasury Regulations related to Section 987 by one year (effective for tax years beginning Jan. 1, 2019). This is pursuant to the Executive Order that President Trump gave to the Treasury in April 2017 to identify and reduce tax regulatory burdens.
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Combating Double Taxation: Foreign Tax Credits and Tax Treaties

Posted 4:00 AM by
The foreign tax credit and its application is complex and can vary widely when looking at state tax liabilities, and the application of tax treaties against state liabilities. A taxpayer that earns income abroad may potentially be subject to double taxation, making the foreign tax credit and tax treaties an important part of the tax filing process.
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Section 987 Regulations: Calculation and Elections

Posted 4:00 AM by
As a follow up to “Section 987 Regulations: Key Considerations” and “Section 987 Regulations: Terminology Explained,” this third and final post in this series will focus on the calculation under the final regulations along with some of the potential elections that can be made related to Section 987 branch remittances.
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New U.S. Reporting Obligations Imposed on Foreign-Owned Disregarded Entities

Posted 4:00 AM by
In December 2016, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued final regulations regarding foreign-owned domestic disregarded entities.
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Section 987 Regulations: Terminology Explained

Posted 4:00 AM by
As a follow up to our “Section 987 Regulations: Key Considerations,” this blog post will help define many of the complex terms included within these regulations. The regulations relate to the methods a taxpayer must use to account for fluctuations in the foreign currency exchange rates when they have business operations that are denominated in a functional currency different than their own.
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International Tax Issues Update: What You Need to Know

Posted 4:00 AM by
There are a couple of changes related to businesses required to file Form 8938 (when they were previously exempt) and individuals who are not eligible for U.S. Social Security Numbers needing to renew their Individual Taxpayer Identification Number (ITIN) numbers that impact the 2016 filing season.
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