foreign tax credit Archives - Schwartz International

Schwartz International, as a Unique International Tax Firm, Loves Challenges!

Leave a Comment / Uncategorized / By Marc Schwartz

For those interested in tax treaty implications of the latest US tax reform, we recently published an article with Tax Notes International that took a specific position on an issue being highly contested in the international tax community. While we did not request anyone to “challenge” our conclusion, we stated that we would love to …

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IRS agrees that French CSG is a Creditable Tax

Leave a Comment / Uncategorized / By Marc Schwartz

The Internal Revenue Service (IRS) has recognized in a June 14th court filing that the French Generalized Social Contribution (CSG) and the Contribution for the repayment of social debt (CRDS), are, in fact creditable taxes for US tax purposes. This ends a 7-year legal battle about whether the CSG and the CRDS were “social taxes” …

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Simone Alting speaks at the GSCPA Decision Makers Conference

Leave a Comment / Firm News, International Accounting, International Business, International Law, International Tax, News & Blog, Team News, Uncategorized / By Marc Schwartz

On Thursday, April 25th Simone Alting spoke about International Tax Policy at the Georgia Society of CPAs (GSCPA) Decision Makers Conference. Here is a snippet of what she covered: Despite budget constraints and key vacancies, the IRS continues to target international issues and assert large penalties. The IRS is focused on FBAR violations, expanded foreign …

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PREVIOUSLY TAXED EARNINGS AND PROFITS (“PTEP”) UNDER THE TCJA

Leave a Comment / Firm News, International Law, International Tax, News & Blog, Uncategorized / By Marc Schwartz

“Oh, how I long for the good ‘old days’ (just 2016, not far back)” Introduction For those that remember, the subpart F rules were introduced in 1962 when statutory rates were extremely high and, until December 31, 2016, we all knew the rules of the game, so to speak. The last major tax reform was …

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Marc Schwartz Participates in International Tax Talk

Leave a Comment / Firm News, International Accounting, International Business, International Law, International Real Estate, International Tax, News & Blog, Team News, Uncategorized / By Marc Schwartz

Marc Schwartz was pleased to participate in the March 21, 2018 panel on international tax reform sponsored by Taylor English. Marc spoke alongside Vivian Hoard, an experienced tax litigator with Taylor English, and Iliana B. Malinov, a partner with HLB Gross Collins, P.C. Vivian moderated as Iliana and Marc focused on the practical implications …

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New Guidance on Forced / Deemed Repatriation Under IRC Section 965

Leave a Comment / News & Blog / By Marc Schwartz

By Marc Schwartz So naïve of me. When will I learn? When Congress passed the December 2017 tax legislation, it created such complexity that my head still hurts. Focusing on the international provisions didn’t reduce the complexity. While I’ll get to the point in a minute, I still feel somewhat bad for the IRS. …

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International Tax Reform 4.0 – Transition Tax on Foreign Earnings – New Guidance

Leave a Comment / News & Blog / By Marc Schwartz

In Notice 2018-07 (“Notice”), the IRS has moved quickly to provide preliminary guidance under Internal Revenue Code Section (“§”) 965, as amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115-97, enacted on December 22, 2017. We’re impressed by …

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Investing in Cuba?

Leave a Comment / Firm News, International Accounting, International Business, International Law, International Real Estate, International Tax, Team News, Uncategorized / By Marc Schwartz

Teaming with Bo Jackson (no, not that Bo Jackson — the Atlanta CPA), SI’s Richard Hartnig and Marc Schwartz revisit various US tax issues related to Cuba. Last year the IRS made a few constructive changes, and we wanted to revisit those as we await the Trump Administration’s Cuba policy. See page 11 for the …

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Anthony Ji Publishes First Article as Part of the SI Team

Leave a Comment / Firm News, International Accounting, International Business, International Tax / By Marc Schwartz

Anthony Ji’s first publication attempt was accepted by Wolters Kluwer in its Global Tax Weekly: a closer look. Anthony’s article focuses on direct versus indirect foreign tax credits, the impact on individuals and the advantages / disadvantages of making an election under Internal Revenue Code Section 962 to claim the benefits of an indirect credit. …

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