The International Tax Corner: Edition 4 The Basic Principles of Residency Residency is a critically important factor in international tax, not just for the US. Why is that? Residency typically determines who can impose tax on worldwide income. We’re going to stick first with the Internal Revenue Code and regulations and at some point, later […]
International Tax Corner: Edition 4 Read More »
The International Tax Corner: Edition 1 What is International Tax? The term International Tax is a misnomer. At least from a US perspective, we use the Internal Revenue Code and its regulations; we use IRS guidance and US court cases. That’s domestic law. We simply use the portions of domestic law that focus on international
International Tax Corner: Edition 1 Read More »
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”
IRS agrees that French CSG is a Creditable Tax Read More »
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
International Tax Training with Ohio-based Firm – Bober Markey Fedorovich Read More »
“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
PREVIOUSLY TAXED EARNINGS AND PROFITS (“PTEP”) UNDER THE TCJA Read More »
We were pleased to have an article written by Marc Schwartz published in the May-June 2018 issue of the Georgia Society of CPAs Current Accounts magazine. The article – “Implications of the International Tax Provision” – summarizes the recent federal international tax reform and its impact in Georgia. Read and share the article: https://www.gscpa.org/Content/Files/Pdfs/Current%20Accounts/M.Schwartz_MayJun18.pdf
International Tax Reform’s Impact on state of Georgia Tax Read More »
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
Marc Schwartz Participates in International Tax Talk Read More »
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.
New Guidance on Forced / Deemed Repatriation Under IRC Section 965 Read More »
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.
Anthony Ji Publishes First Article as Part of the SI Team Read More »
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