[India Part II: Institute of Chartered Accountants of India] From Jaipur, Marc flew to Pune where he met fellow Corporate Tax Alliance member Ameya Kunte, Founder of Globeview Advisors LLP, for multiple presentations to business leaders. He focused on significant India-US cross-border Income and Estate Tax issues – and of course made sure the crowds […]
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[India Part I: Allinial Global APAC Roadshow (Delhi) & The APAC Regional Conference (Jaipur)] Our International Tax Nerd In-Chief doesn’t sit around for too long. Late July meant pacing a friend for 19 miles of a 200-mile endurance race in Colorado at altitudes ranging from 9,500 and 11,500 feet before traveling to India to speak
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International Tax Corner: Edition 10 Introduction, and perhaps a grammar lesson My mom taught me not to use four-letter words. Unfortunately, as an International Tax Nerd that’s not always possible. PFIC. PFIC. PFIC. OK, true, that’s not really a four-letter word. For you English grammar folks, it’s an acronym. But it allows us to
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In the dynamic world of nonprofit organizations, the intersection of international tax regulations and operational expansion presents a unique set of challenges. Recently, this topic gained significant attention at the 2024 TXCPA’s Nonprofit Organizations Conference in Dallas, TX. Marc was invited by Elaine L. Sommerville of Sommerville & Associates, P.C. to share insights into the
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The International Tax Corner: Edition 9 Navigating the Complexity & Inequity of the US Tax Code There are a lot of problems in this world. Why do some get more attention than others? Why do we read about some in the newspaper daily while others rarely get a mention? Politics; power; money; biases – it’s
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The International Tax Corner: Edition 8 Anti-Deferrals and Foreign Investments If you’ve stayed awake so far through Edition 7, you know the definition of a US Shareholder under IRC §951(b) – For purposes of this title, the term “United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in
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The International Tax Corner: Edition 7 Why does the US Tax Code Punish Foreign Investment? Since 1962, the US made it difficult for US taxpayers to defer taxation on passive income, e.g., dividends and interest on investments held through a foreign company owned by a US shareholder (more on this later). On the other hand,
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The International Tax Corner: Edition 6 Tax Residency under the Internal Revenue Code (“Code”) and Treaties This edition focuses on individuals, not companies or other legal entities. In Edition 4, we discussed the concept of residency and its importance. The jurisdiction of residency may impose tax on worldwide income. If you’ve been reading with us,
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The International Tax Corner: Edition 5 What are Treaties? In the area of international taxation, countries enter into various treaties (agreements). While the most common one deals with income taxation, others deal, separately, with social security and estate, inheritance, and gift taxes. A treaty is a contract, i.e., a legally binding agreement between sovereign states.
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Australia, with its vibrant economy and bustling financial sector, recently played host to Marc for a month-long visit. His journey Down Under wasn’t just about sightseeing; it was a productive excursion filled with speaking engagements, insightful discussions, and fruitful meetings all about international tax. First Stop: Bentleys Marc kicked off his Australian tour by taking
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