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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The International Tax Corner: Edition 4 The Basic Principles of Residency Residency is a critically important factor in international tax, not just for the US. Why is that? Residency typically determines who can impose tax on worldwide income. We’re going to stick first with the Internal Revenue Code and regulations and at some point, later
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Our Most Senior Nerd, Paul, traveled to Milan, Italy – high fashion center of the world… high cost! Amid his backdrop, Paul actively participated in lively discussions on two important topics involving cross-border taxation: (1) centralized procurement activities; and (2) employee mobility (employer and employee). The participants were seasoned professionals in the Corporate Tax Alliance
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