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International Tax Technical Update- September 2018

MOVING EXPENSESTHE DISALLOWANCE OF MOVING EXPENSES AND ITS IMPACT ON DOMESTIC AND GLOBAL MOBILITY PROGRAMS

On December 22, 2017, the enactment of tax reform (also known as the Tax Cuts and Jobs Act) brought about widespread changes to includable and excludable items, with moving expenses being one of the most notable. Read more

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The GILTI Effect: Tax Reform And Global Intangible Low-Taxed Income

What is GILTI?
The Global Intangible Low-taxed Income (GILTI) is a new provision, enacted as a part of tax reform legislation. Mechanically, it functions as a global minimum tax and introduces a lot of issues for all U.S. shareholders of controlled foreign corporations (CFCs) – especially individuals and partnerships. Read more

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International Tax Technical Update- April 2018

CHANGES IN SECTION 965 SPECIFIED FOREIGN CORPORATIONS’ TAX YEARS

Summary

On February 13, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”) issued Rev. Proc. 2018-17 (the “Rev. Proc.”).  The Rev. Proc. provides additional guidance under Section 965, Treatment of deferred foreign income upon transition to participation exemption system of taxation, as amended by the “Tax Cut and Jobs Act,” which was enacted on December 22, 2017.  In particular, the Rev. Proc. provides guidance regarding certain changes in Section 965 specified foreign corporations’ tax years. Read more

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What to do if You are Out of the Country on Tax Day

Out of country

The IRS has different definitions and rules for being ‘out of the country’ on Tax Day.

By Bethany Bouw

There are a variety of ways one may be considered ‘out of the country’ on the due date of individual income tax returns (April 17, 2018). In regards to filing the automatic two-month extension, the IRS has a slightly complicated definition of ‘out of the country’. You will want to make sure that you fully understand their definition in order to know when your due date is and how best to extend. Read more

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Do I Qualify for the Automatic Two Month Extension?

Two Month Extension

Tax Day this year is April 17th, though some may qualify for the two month extension.

By Bethany Bouw

The due date for individual income tax returns (April 17, 2018) is nearly upon us. Some of you may be wondering if you qualify for the automatic two-month extension. Ryan & Wetmore is here to help you with your extension concerns. Read more

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International Tax Technical Update- March 2018

U.S. TAX REFORM AS IT RELATES TO MOBILE EMPLOYEES, BOTH DOMESTIC AND INTERNATIONAL

The U.S. Tax Cuts and Jobs Act that was signed by President Trump on December 22, 2017, is said to be the most significant tax legislation in over three decades.  Most of the changes that were introduced went into effect January 1, 2018.  This alert will highlight several areas of the tax reform legislation that domestic relocation program managers and global mobility program managers should consider as it relates to their programs, their company and their assignees.  Read more

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I Married a Non-Resident, Non-Citizen…now what?

non-resident

Your tax status changes when you get married, especially if your new spouce is a not a US resident.

By Bethany Bouw

In the flush of love and planning a wedding, perhaps the last thing on your mind was how the marriage might impact your income tax filings going forward. You were probably so busy planning how to deal with the immigration paperwork so you could simply reside in the same nation, that you may have not given your tax situation much thought. We at Ryan & Wetmore are here to help with some filing tips to get you started in the right direction.  These eight tips will help clear things up for you, so you can get back to focusing on your new spouse instead of your new tax status! Read more

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Foreign Trust Annual Reporting – Who, What, When, Where, Why?

Foreign Trust

Reviewing the Who, What, When, Where, and Why of foreign trust reporting.

By Bethany Bouw

Perhaps you remember from grade school considering the five W questions for a topic to make sure you really comprehended the material. Well, foreign trust reporting (Form 3520-A) is a topic that deserves this treatment to make sure you do not miss a crucial step and end up with a late filing. Let’s walk through the five W’s together: Read more

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Technical Update- International Taxation February 2018

TREASURY PROVIDES ADDITIONAL GUIDANCE UNDER SECTION 965 AND GUIDANCE IN CONNECTION WITH THE REPEAL OF SECTION 958(B)(4)

Summary

On January 19, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”) issued Notice 2018-13 (the “Notice”).  The Notice provides additional guidance under Section 965, Treatment of deferred foreign income upon transition to participation exemption system of taxation, as amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115-97 (known as the Tax Cut and Jobs Act), which was enacted on December 22, 2017.   Read more

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Summary of International Provisions Included in the Tax Cuts and Jobs Act

Summary

On November 2, 2017, the House of Representatives released the Tax Cuts and Jobs Act (the “Bill”). The Bill includes a broad set of proposed changes to overhaul the current U.S. tax system, including rules on how foreign income and foreign persons would be taxed. The Bill’s key proposals relating to the taxation of foreign income and foreign persons are summarized below.[1] 

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