repatriation

Simone Alting speaks at the GSCPA Decision Makers Conference

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

“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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New Guidance on Forced / Deemed Repatriation Under IRC Section 965

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

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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IFA USA

Marc Schwartz Participates as a Panelist at Atlanta IFA Seminar

On May 27, 2015 the IFA (International Fiscal Association) USA Atlanta Region Chapter held a seminar on various international tax issues. Marc Schwartz was invited to participate in a panel discussing Internal Revenue Code 956, Subpart F and related repatriation issues impacting both individuals and companies. Other items the panel discussed include APB 23, deferral …

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