So You Think You Want to Expatriate…

October 25, 2018
Expatriate

Anyone thinking about expatriating needs to be aware of the associated tax and legal responsibilities.

By Bethany Bouw, CPA

We see much in the news about people expatriating – jokes related to a political climate (regardless of administration), trying to avoid tax (think that Facebook co-founder who renounced citizenship), and those who have spent the majority of their lives abroad, etc. Unfortunately, relinquishing citizenship and ending long-term residency is not as easy as mailing in your passport or green card and booking a flight with your belongings. There is much more involved from a tax perspective when expatriating and it should be done with input from an attorney and a qualified tax professional. Below you will find 10 starting questions and answers regarding expatriation and Form 8854, Initial and Annual Expatriation Statement. Read more

Foreign Currency: What Does The IRS Say About It?

October 25, 2018

Foreign CurrencyBy Bethany Bouw, CPA

More now than ever people travel, work, and live all around the world. Therefore, understanding how to deal with foreign currency is becoming even more relevant. Taxpayers who have transactions in foreign currencies often wonder what they need to report and how they get the foreign currency into US dollars. Let’s review four of the most widely asked question regarding a taxpayer’s responsibility when dealing with foreign currency. Read more

Foreign Taxation Technical Update: Section 965 Guidance

October 11, 2018

Summary

On October 1, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued Notice 2018-78 (the Notice). The Notice provides guidance with respect to the basis election under Prop. Reg. §1.965-2(f)(2), the application of rules for disregarding certain assets for determining aggregate foreign cash position in Prop. Reg. §1.965-3(b) to consolidated groups and relief in connection with Hurricane Florence. Read more

International Tax Technical Update- October

October 3, 2018

TREASURY ISSUES PROPOSED REGULATIONS FOR GLOBAL INTANGIBLE LOW-TAXED INCOME, SECTION 951A

Summary

On September 13, Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations (REG-104390-18, hereinafter, the Proposed Regulations) implementing Section 951A. Read more

International Tax Technical Update- September 2018

September 26, 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

Foreign Entity Filings- Forms 8865 and 8858

August 29, 2018
8865 and 8858

U.S. taxpayers who do business globally are well aware of the tax implications involved. Forms 8865 and 8858 are lesser known, but important for foreign corporations to understand.

By Bethany Bouw, CPA

Taxpayers who have foreign businesses are often surprised to hear there are filing requirements to disclose their business. If you are familiar with the basics of international business, you may know this is true of foreign corporations. The same is true of partnerships, sole proprietors, other foreign disregarded entities and more. In many cases, taxpayers assume that if they keep most aspects of their business abroad, that the IRS will have no interest in them. Unfortunately, they are incorrect.

Read more

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

August 28, 2018

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

Reporting US Single Member LLCs with Foreign Ownership

July 25, 2018
Single Member LLC

Reporting your foreign owned single member LLC will be different going forward.

By Bethany Bouw, CPA

If you are a foreign person who has a US single member LLC, there are some new developments that you should be aware of for tax year 2017. Reporting policies regarding foreign ownership of single-member LLCs have recently changed. First and foremost, it is important to know your status – US or foreign. To determine this, you should check the IRS rules and contact a lawyer. Read more

10 Tips for Reporting Certain Foreign Corporations

July 25, 2018
Form 5471

Reporting Form 5471 may be confusing, though it is necessary for many who own foreign corporations.

By Bethany Bouw, CPA

Foreign corporations sound innocuous enough but when you delve into the reporting requirements it opens up a Pandora’s box of complex tax issues. There are so many aspects to consider in preparing to report foreign corporations and there has been a lot in the news lately regarding foreign corporations due to the new tax reform. Read more

International Tax Technical Update- July 2018

July 18, 2018

What is BEAT?

Enacted as part of the Tax Cuts and Job Act (TCJA), the new “base erosion and anti-abuse tax” (BEAT) can apply to certain corporations that make “base erosion payments” paid or accrued in taxable years beginning after December 31, 2017. Read more