International Tax Nerd-In-Chief, Marc Schwartz, started the year off in Akron, Ohio visiting colleagues at Bober Markey Fedorovich (BMF).
Paul Tadros unfortunately didn’t make it as his flight was cancelled – ugh! As do many other CPA firms across the country, BMF calls on us to assist with their clients’ international issues. We are grateful for the opportunity to provide this service and to continue to visit our clients.
Marc may not have been prepared for the snow and cold temperatures that greeted him, but he was prepared to provide an overview international tax presentation to BMF’s 40-person tax team. The key focus was International Tax Items Non-Specialists Need to Know. We enjoy these discussions to help our CPA firm clients identify important issues, whether dealing with individuals or companies, inbound or outbound. Of course, another constant theme is working with US citizens and Green Card holders that might not be in full compliance given the highly complex US income and information reporting rules – Can you say 5471? 5472? 3520? FBAR / FinCEN 114?
Discussions were centered around –
- The Tax Cut and Jobs Act (TCJA) changes to inventory sourcing rules and the direct impact on BMF’s clients. A large portion of the discussions focused on why the “check the box” (entity classification election) rules were never a panacea and how certain structures with check the box elections may yield a bad foreign tax credit (FTC) answer based on the sourcing changes.
- Anti-hybrid rules that have been popping up, largely in the EU. This, on top of Canada’s rules which often negatively impact cash repatriation to the US.
- The seemingly omnipresent anti-deferral rules, including GILTI (global intangible low-taxed income), the remainder of the Subpart F rules and PFIC (passive foreign investment company).
- The Streamlined Filing Compliance Procedures and other avenues to bring taxpayers into compliance.
Regardless of your firm’s size, your clients likely have international needs, even if they don’t know it. Filing season is upon us, and understanding rules and regulations is crucial. As International Tax Nerds, we love to share knowledge and provide value to other tax professionals and partners – thanks to the tax team at BMF for sharing that passion with us!
About Schwartz International
The International Tax Nerds at Schwartz International team with individuals, companies of all sizes and other accounting and law firms to provide practical international tax, compliance, and legal advice.
We live and breathe international tax daily, and since we’ve lived in various countries, we understand the diverse cultural challenges you face. We work in four key areas: International Tax Advisory; International Tax Compliance; Cryptocurrency; and Law via our sister company, The Schwartz Law Firm.
About Bober Markey Fedorovich
Bober Markey Fedorovich (BMF) has provided clients with quality service throughout Northeast Ohio since 1959. They specialize in accounting, audit, tax, business advisory services, litigation support, valuation, and transaction advisory services, with a focus on privately held businesses, private equity groups and SEC companies.
BMF is amongst only fifty firms nationwide to receive the “Best of the Best Firm” in 2021 by INSIDE Public Accounting. Recently, Richard C. Fedorovich has been selected as the 2023 recipient of the H. Peter Burg Economic Development Leadership Award, presented by the Greater Akron Chamber.