GILTI

Softball shirt with various company sponsorship logos

Schwartz International in the Infield and Outfield

As we transition into Spring, some of the International Tax Nerds have found a great outlet for this busy tax season. The budding community of Serenbe has a recreational softball league, and Schwartz International is proud to be one of its sponsors and participants. The primary goals are simply not getting injured ( ???? ) …

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Marc Shares Practical Implications of GILTI at the 2019 CPAmerica International Group Meeting

The International Tax Nerds continue to travel as Marc was invited to participate in CPAmerica’s 2019 International Group Meeting in Ft. Lauderdale, Florida. On December 5, Marc presented on the Practical Implications of GILTI (Global Intangible Low-Taxed Income) before an audience of practitioners from the US, Canada, Mexico, South America and throughout Europe. Marc even …

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More Milan Tax Discussions for Schwartz International

On September 9, Marc Schwartz — our chief International Tax Nerd — and Studio Pugliese partners met in Milan, Italy to discuss the new US tax law’s impact on Italy-US investment. Marc was a little winded after a harrowing taxi ride from his first meeting that day with another accounting firm, but all turned out …

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Schwartz International Tackles New US Tax Law’s Impact on Italy-US Investment

On September 9, Schwartz International and Pirola Pennuto Zei & Associati partners met in Milan, Italy to discuss the new US tax law’s impact on Italy-US investment. The teams focused on general changes in the US law, including the infamous GILTI (global intangible low-taxed income) and related items, Italy’s anti-deferral rules and brainstormed on cross-border …

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

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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International Tax Training with Ohio-based Firm – Bober Markey Fedorovich

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 …

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Marc & Simone discuss GILTI and FDII rules at the North Atlanta Tax Council

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 …

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

“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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