Marc Schwartz was pleased to be invited to present an international tax training seminar to the Cleveland and Akron, Ohio-based firm of Bober Markey Fedorovich (“BMF”) on January 31. With Ohio’s negative 4 degree temperature that week, Marc is glad his home-base is Atlanta and he presented via webinar.
Marc provided an update on international tax topics to BMF’s tax team, discussing a broad overview of the policies the law is intended to support, including the concept that tax changes might motivate companies to “move jobs back home”. He also discussed details of the Participation Exemption of IRC §245A, the global intangible low-taxed income (GILTI) rules of IRC §951A, the foreign derived intangible income (FDII) rules of IRC §250 and the hybrid rules of IRC §267A. As Marc also works with taxpayers with exposure related to international activities, he shared the latest on FBAR / FinCEN 114, including an overview of the new voluntary disclosure procedures released after the Offshore Voluntary Disclosure Program recently ended, as well as other ways taxpayers can come back into compliance.