Marc Schwartz and Simone Alting were pleased to be invited to present an update on international tax topics to the North Atlanta Tax Council (NATC) on January 18. They discussed 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”. They also discussed details about 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. Another important item included the latest on FBAR / FinCEN 114, including an overview of the new voluntary disclosure procedures released after the Offshore Voluntary Disclosure Program (OVDP) recently ended, as well as other ways taxpayers can come back into compliance.
Thanks, NATC, for a rewarding few hours.