Determine if You’re GILTI Using this Calculator
A Good First Step On Your Journey To GILTI Compliance Or Avoidance In a blog post I wrote a few weeks ago, I talked about two new international tax...
Filtered by Tag: International Tax
International Tax Accounting: Mandatory Repatriation “Toll Tax” of Income Earned by Controlled Foreign Entities
The Tax Cuts and Jobs Act signed into law by President Trump has been at the forefront of the national news since its passage in December. There are...
Global Intangible Low Tax Income (GILTI) and Foreign-Derived Tangible Income Taxes (FDII)
New International Tax Provisions for 2018 and Beyond With the recently enacted tax reform two new terms have been introduced into the international...
What Is a Foreign Trust and How Does It Affect U.S. Tax Reporting?
Over the past few decades, the IRS has made an effort to increase awareness of reporting regulations for foreign trusts. If you are a U.S. taxpayer...
Canada Death Tax System vs. USA Death Tax System: A Comparative Overview
“In the Great White North, there’s 5 pin bowling, and in the U.S., there’s 10 pin…” -Bob and Doug McKenzie Funny, but that simple phrase sums up the...
Transfer Pricing Methods for Intangible Property
In recent years the IRS has focused more heavily on the transfer pricing of intangible property. Section 482 of the regulations provide guidelines so...
Got Intercompany Transactions? Transfer Pricing Under Increased Scrutiny
Does your company have intercompany transactions? Do the transactions cross over multiple foreign local jurisdictions? If you answered yes to either...
Basics of U.S. Transfer Pricing for Non-U.S. Businesses
If your company has a U.S. subsidiary, you will most likely have some transfer pricing considerations that need to be addressed. Transfer pricing can...