International Accounting

A Foreign Trust Investing In The US: ‘Ordinary’ Or ‘Business’ Trust?

reprinted with permission from Global Tax Weekly, Wolters Kluwer by Marc Schwartz and Paul Tadros All Section references are to the US Internal Revenue Code, 1986, as amended and the US Department of the Treasury regulations (collectively, “Code”) promulgated thereunder unless stated otherwise; Unless stated otherwise, the terms “tax” and “taxation” mean income tax; Unless …

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More Frustration Over Tax Treaty Delays

The U.S has income tax treaties with more than 60 countries, helping to advance global trade by reducing double taxation and providing more certainty in international business, among other items. In order to serve their purpose, income tax treaties must be updated to parallel growing developments in tax policy, the international economy, and new treaties …

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Anthony Ji Publishes First Article as Part of the SI Team

Anthony Ji’s first publication attempt was accepted by Wolters Kluwer in its Global Tax Weekly: a closer look. Anthony’s article focuses on direct versus indirect foreign tax credits, the impact on individuals and the advantages / disadvantages of making an election under Internal Revenue Code Section 962 to claim the benefits of an indirect credit. …

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Tadros and Schwartz Discuss International Tax in Madrid

Paul Tadros and Marc Schwartz participated in the Corporate Tax Alliance’s (CTA) annual meeting last week in Madrid, Spain (October 2-3). Tax professionals representing 20+ jurisdictions, ranging from the western hemisphere, Europe and Asia met to discuss current trends in global tax, including BEPS (base erosion and profit shifting), tax treaties and other items related to our …

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IFA USA

Marc Schwartz Participates as a Panelist at Atlanta IFA Seminar

On May 27, 2015 the IFA (International Fiscal Association) USA Atlanta Region Chapter held a seminar on various international tax issues. Marc Schwartz was invited to participate in a panel discussing Internal Revenue Code 956, Subpart F and related repatriation issues impacting both individuals and companies. Other items the panel discussed include APB 23, deferral …

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