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International Tax

International Tax Updates in Response to the COVID-19 Emergency

Posted 5:15 PM by
It has been a tumultuous few weeks for the United States (and around the world) as we continue to deal with the ongoing COVID-19 emergency. There have been many questions from taxpayers who are wondering how to move forward, specifically regarding how and when to file their 2019 tax returns.
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Complying With the Often Misunderstood International Boycott Reporting Requirements

Posted 3:45 PM by
The Internal Revenue Code, while primarily used to generate tax revenue for the government, is often used to incentivize or penalize various U.S. policy decisions. Section 999 is one such section that is driven by broader U.S. policy goals.
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ICLEF Seminar: International Update: GILTI and Structure Considerations

Posted 3:45 PM by
Katherine Malarsky, director in KSM’s Tax Services Group, will examine new tax developments as they relate to international tax at the Indiana Continuing Legal Education Forum’s (ICLEF) “Practical Tax Law: Speed Dating with Taxes” seminar Dec. 10.
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Final GILTI Regulations Provide Some Relief to Taxpayers

Posted 1:15 PM by
The Tax Cuts and Jobs Act of 2017 added a new anti-deferral rule known as Global Intangible Low-Taxed Income (GILTI). The GILTI provisions impact taxpayers that own an interest in certain foreign corporations that are classified as controlled foreign corporations (CFC). Below is a brief background on the basic GILTI rules as well as highlights of significant developments in the final regulations that were issued in June 2019.
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Determining the Category of Filer for Form 5471 With Respect to Ownership of Foreign Corporations

Posted 5:30 PM by
The Tax Cuts and Jobs Act (“TCJA”) that was passed at the end of 2017 was meant to simplify the tax code. However, in the international tax realm, the complexity has only increased. This is certainly true of the revised form and instructions for Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, as of December 12, 2018 for the 2018 tax filing season. These revisions significantly change the form, and the instructions expand the categories of filers for this form.
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The Increased Importance of Income Sourcing in a Post-Tax Reform World

Posted 8:00 PM by
The Tax Cuts and Jobs Act of 2017 (TCJA), signed into law in late 2017, included significant changes to the tax environment in the United States. One of the largest changes was the addition of the qualified business income (QBI) deduction. The QBI deduction allows for a deduction of up to 20 percent of the qualified business income from partnerships, limited liability companies (LLCs), S corporations, trusts, estates, and sole proprietorships. Learn more about the QBI deduction.
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Malarsky to Speak on International Tax at ICLEF Seminar

Posted 3:00 PM by
Katherine Malarsky, director in KSM’s Tax Services Group, will discuss international tax reform at an Indiana Continuing Legal Education Forum (ICLEF) seminar on Dec. 11. The event, held at the ICLEF Conference Facility in Indianapolis, will educate non-tax attorneys of all backgrounds on tax law updates spurred by recent tax reform. The fast-paced seminar, worth three CLE credits, will feature nine different speakers giving 20-minute presentations.
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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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U.S. Partnerships With Foreign Partners: A Look at Withholding and Reporting Obligations

Posted 12:28 PM by
U.S. partnerships with foreign partners are subject to very complex tax laws. The main source of that complexity stems from additional withholding and reporting obligations imposed on the partnership.
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