[India Part I: Allinial Global APAC Roadshow (Delhi) & The APAC Regional Conference (Jaipur)] Our International Tax Nerd In-Chief doesn’t sit around for too long. Late July meant pacing a friend for 19 miles of a 200-mile endurance race in Colorado at altitudes ranging from 9,500 and 11,500 feet before traveling to India to speak […]
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The International Tax Corner: Edition 9 Navigating the Complexity & Inequity of the US Tax Code There are a lot of problems in this world. Why do some get more attention than others? Why do we read about some in the newspaper daily while others rarely get a mention? Politics; power; money; biases – it’s
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The International Tax Corner: Edition 8 Anti-Deferrals and Foreign Investments If you’ve stayed awake so far through Edition 7, you know the definition of a US Shareholder under IRC §951(b) – For purposes of this title, the term “United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in
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The International Tax Corner: Edition 7 Why does the US Tax Code Punish Foreign Investment? Since 1962, the US made it difficult for US taxpayers to defer taxation on passive income, e.g., dividends and interest on investments held through a foreign company owned by a US shareholder (more on this later). On the other hand,
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The International Tax Corner: Edition 6 Tax Residency under the Internal Revenue Code (“Code”) and Treaties This edition focuses on individuals, not companies or other legal entities. In Edition 4, we discussed the concept of residency and its importance. The jurisdiction of residency may impose tax on worldwide income. If you’ve been reading with us,
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The International Tax Corner: Edition 5 What are Treaties? In the area of international taxation, countries enter into various treaties (agreements). While the most common one deals with income taxation, others deal, separately, with social security and estate, inheritance, and gift taxes. A treaty is a contract, i.e., a legally binding agreement between sovereign states.
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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
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