This document discusses reporting the results of foreign operations for US tax purposes. It covers obtaining financial and structural information from overseas affiliates, key issues in reviewing Form 5471 for foreign corporations, and computing earnings and profits to reconcile with financial statements. Challenges obtaining reliable information from foreign entities are also addressed, as are risks of mistakes on Form 5471 that could result in penalties.
In general terms, this is one of the most frequent questions we get from prospective clients. So then, How do you file US tax returns while in Canada?
The first question we need to ask is whether you’re actually required to file US tax returns. Generally speaking, US citizens and Green Card holders are required to file US tax returns regardless of where they live. Therefore Americans living in Canada, whether they’ve recently moved to Canada or have been in the country their entire lives are required to file US tax returns in addition to their regular Canadian tax returns.
The document summarizes key changes to the IRS Form 990 required for nonprofit organizations. The redesigned form has an increased focus on governance, executive compensation, fundraising, and reporting of related organizations and activities. It provides more transparency through additional questions around policies, compensation, and transactions with interested parties. Organizations should review the new requirements and ensure their governance policies and procedures address the additional disclosure areas.
Aubrey Batzinger has over 6 years of experience in taxation. She currently works as a Tax Associate II - Six Sigma Specialist at Raytheon in Waltham, MA where she researches international tax opportunities, provides tax analysis and guidance on international contracts, and manages processes related to tax calculations and forms. Previously, she worked as a Tax Associate at Raytheon where she prepared state tax returns and completed a Six Sigma project. She also has experience preparing tax returns as a Tax Assistant at Jeffrey Morgen C.P.A. Firm.
Fiduciary Protection: Is Your Retirement Plan Ready for a DOL or IRS Audit?Citrin Cooperman
The document discusses retirement planning challenges presented by the COVID-19 pandemic. It notes that the pandemic severely impacted many businesses, leading to high unemployment. While testing and cases have improved, there is still uncertainty around reopening plans and potential summer spikes. The stock market rebounded from initial declines but volatility remains. The document provides tips for retirement plan participants and sponsors, such as maintaining a diversified portfolio and long-term focus during volatile times. It emphasizes continuing retirement contributions where possible.
This document summarizes the key benefits, disadvantages, and processes involved in establishing and maintaining tax-exempt non-profit and charitable organizations. It outlines the limited liability protection, tax exemptions, and eligibility for tax-deductible donations that non-profits receive. However, non-profits also face limitations on income sources and inability to distribute profits. To establish tax-exempt status, organizations must file paperwork with the IRS including organizing documents and financial statements. Non-profits must also comply with ongoing restrictions and maintenance requirements at the federal, state, and local levels to preserve their tax-exempt status.
The document discusses the requirements of IAS 1 regarding the presentation of financial statements. It provides an overview of the components that must be included in a complete set of financial statements according to IAS 1, such as the statement of financial position, statement of comprehensive income, statement of changes in equity, statement of cash flows, and accompanying notes. It also covers the principles of fair presentation, going concern assumption, materiality, and classifications of assets and liabilities as current vs. non-current.
- Total net revenue for JPMorgan Chase in Q1 2010 was $27.7 billion, an 11% increase from Q1 2009. Net income was $3.3 billion, up 55% from Q1 2009.
- Noninterest expense increased 34% to $16.1 billion due primarily to a $2.2 billion increase in other expense. Provision for credit losses decreased 4% to $7 billion.
- Key business lines reported the following net income: Investment Bank $2.5 billion, Retail Financial Services -$131 million, Card Services -$303 million, Commercial Banking $390 million.
Brian attended the World Conference hosted by GGI annually. It was held in Cape Town, South Africa this year. His topic was on the tax implications of bring business from abroad to the U.S.
In general terms, this is one of the most frequent questions we get from prospective clients. So then, How do you file US tax returns while in Canada?
The first question we need to ask is whether you’re actually required to file US tax returns. Generally speaking, US citizens and Green Card holders are required to file US tax returns regardless of where they live. Therefore Americans living in Canada, whether they’ve recently moved to Canada or have been in the country their entire lives are required to file US tax returns in addition to their regular Canadian tax returns.
The document summarizes key changes to the IRS Form 990 required for nonprofit organizations. The redesigned form has an increased focus on governance, executive compensation, fundraising, and reporting of related organizations and activities. It provides more transparency through additional questions around policies, compensation, and transactions with interested parties. Organizations should review the new requirements and ensure their governance policies and procedures address the additional disclosure areas.
Aubrey Batzinger has over 6 years of experience in taxation. She currently works as a Tax Associate II - Six Sigma Specialist at Raytheon in Waltham, MA where she researches international tax opportunities, provides tax analysis and guidance on international contracts, and manages processes related to tax calculations and forms. Previously, she worked as a Tax Associate at Raytheon where she prepared state tax returns and completed a Six Sigma project. She also has experience preparing tax returns as a Tax Assistant at Jeffrey Morgen C.P.A. Firm.
Fiduciary Protection: Is Your Retirement Plan Ready for a DOL or IRS Audit?Citrin Cooperman
The document discusses retirement planning challenges presented by the COVID-19 pandemic. It notes that the pandemic severely impacted many businesses, leading to high unemployment. While testing and cases have improved, there is still uncertainty around reopening plans and potential summer spikes. The stock market rebounded from initial declines but volatility remains. The document provides tips for retirement plan participants and sponsors, such as maintaining a diversified portfolio and long-term focus during volatile times. It emphasizes continuing retirement contributions where possible.
This document summarizes the key benefits, disadvantages, and processes involved in establishing and maintaining tax-exempt non-profit and charitable organizations. It outlines the limited liability protection, tax exemptions, and eligibility for tax-deductible donations that non-profits receive. However, non-profits also face limitations on income sources and inability to distribute profits. To establish tax-exempt status, organizations must file paperwork with the IRS including organizing documents and financial statements. Non-profits must also comply with ongoing restrictions and maintenance requirements at the federal, state, and local levels to preserve their tax-exempt status.
The document discusses the requirements of IAS 1 regarding the presentation of financial statements. It provides an overview of the components that must be included in a complete set of financial statements according to IAS 1, such as the statement of financial position, statement of comprehensive income, statement of changes in equity, statement of cash flows, and accompanying notes. It also covers the principles of fair presentation, going concern assumption, materiality, and classifications of assets and liabilities as current vs. non-current.
- Total net revenue for JPMorgan Chase in Q1 2010 was $27.7 billion, an 11% increase from Q1 2009. Net income was $3.3 billion, up 55% from Q1 2009.
- Noninterest expense increased 34% to $16.1 billion due primarily to a $2.2 billion increase in other expense. Provision for credit losses decreased 4% to $7 billion.
- Key business lines reported the following net income: Investment Bank $2.5 billion, Retail Financial Services -$131 million, Card Services -$303 million, Commercial Banking $390 million.
Brian attended the World Conference hosted by GGI annually. It was held in Cape Town, South Africa this year. His topic was on the tax implications of bring business from abroad to the U.S.
A Highlighted Analysis of Proposed Section 965 RegulationsCitrin Cooperman
This document summarizes key aspects of proposed regulations related to Section 965 of the tax code. Some highlights include:
- The definition of a specified foreign corporation and how ownership is determined.
- How accumulated post-1986 deferred foreign income is calculated, including reductions for distributions, foreign taxes, and deficits.
- Rules for determining a deferred foreign income corporation and earnings and profits deficit foreign corporation.
- How the aggregate foreign cash position is measured across multiple cash measurement dates.
- Rules around foreign tax credits, installment payments, acceleration events, and S corporation shareholder deferral elections.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
Solution Manual Advanced Accounting 9th Edition by Baker Chapter 14Saskia Ahmad
The document discusses SEC reporting requirements for public companies. It provides answers to multiple-choice questions covering topics such as the legal authority of the SEC, securities acts of 1933 and 1934, SEC forms like 10-K and 8-K, registration statements, and the Foreign Corrupt Practices Act. It also includes solutions to cases analyzing objectives of securities acts, roles of the SEC and FASB, information in proxy statements, and required disclosures in Form 10-Ks.
This document outlines the key documents needed for US expat tax preparation. It discusses providing a tax questionnaire, prior year's tax return, and travel calendar. It also details the documents needed for reporting income sources like wages, interest, dividends, stocks, real estate transactions, pensions, annuities, social security benefits, and other income. Finally, it discusses documents for deductions like interest and taxes paid, foreign housing expenses, dependents, and other deductions. It advises expat taxpayers to contact issuers if any tax documents seem to be missing.
Accounting for COVID-19 Funding for Post-Acute OrganizationsCitrin Cooperman
This document provides a summary of a webinar discussing various funding opportunities and tax provisions for healthcare organizations in response to the COVID-19 pandemic. It outlines programs like the Provider Relief Fund, Medicare accelerated payments, the Paycheck Protection Program, and tax credits for paid sick/family leave and employee retention. For each program, it discusses eligibility, allowable uses of funds, reporting requirements, repayment terms, and tax implications. The webinar aims to help organizations navigate relief options and ensure compliance to maximize available funding.
The document provides an overview of the 2003 Schools Workshop and guidance for auditing schools for the 2002-2003 fiscal year. Key points included changes to financial reporting requirements to comply with GASB 34, evaluating fundraising activities and the use of restricted funds, ensuring proper treatment of I-728 moneys, and current hot topics like the authority of districts to conduct general fund fundraising and the applicability of competitive bidding requirements. Auditors were instructed to focus on areas like enrollment trends, financial condition indicators, and the proper categorization of fund balance reserves and designations.
Solution Manual Advanced Financial Accounting by Baker 9th Edition Chapter 16Saskia Ahmad
Solution Manual, Advanced Accounting, Thomas E. King, Cynthia Jeffrey, Richard E. Baker, Valdean C. Lembke, Theodore Christensen, David Cottrell, Richard Baker, Advanced Financial Accounting, Advanced Financial Accounting by Baker Chapter 18, Advanced Financial Accounting by Baker Chapter 18 9th Edition, 9th Edition,
This document contains chapter 4 from an accounting textbook on consolidation of wholly owned subsidiaries. It includes questions and answers on consolidation topics such as:
- The purpose of eliminating entries in consolidation vs adjusting entries
- How differentials arise from acquisitions and how they are treated
- How a subsidiary's equity accounts are eliminated in consolidation
- How pushdown accounting can eliminate differentials
It also includes case studies on:
- Why consolidation is necessary to prepare consolidated financial statements
- Issues around presenting consolidated financial statements for a company with diverse subsidiaries
- Treatment of an unprofitable subsidiary in consolidation
- Assigning an acquisition differential to a subsidiary's assets and liabilities
- Implications of a subsidiary having negative
The document discusses additional consolidation reporting issues including:
- Cash flows from operations cannot be easily incorporated into the existing three-part workpaper format because both beginning and ending consolidated balance sheet totals are needed to determine cash flows for the period.
- Dividends paid to noncontrolling shareholders are included in the consolidated cash flow statement but not the consolidated retained earnings statement.
- The indirect method of preparing the statement of cash flows focuses on reconciling net income to cash flows from operations, but does not report explicit payments to suppliers.
- The document discusses partnership liquidation, including definitions, procedures, and accounting treatments.
- A simple partnership liquidation involves one cash distribution where partners receive amounts equal to their pre-distribution capital account balances.
- Priority rankings for distributing assets in liquidation are: 1) amounts owed to non-partner creditors and partners other than for capital and profits, and 2) amounts due to partners based on remaining assets after liabilities are paid.
Speeding Through 2020 Auto Webinar Series - What's Next for PPP?Citrin Cooperman
This document summarizes key information about the Paycheck Protection Program (PPP) loan forgiveness process.
It outlines the different forgiveness applications (3508S, 3508EZ, 3508), what they are used for, and the timeline for applying for forgiveness. It walks through the components of the 3508 application including documenting payroll costs, reductions to loan forgiveness amounts, and eligible non-payroll expenses. It also discusses recent developments like additional disclosure requirements and safe harbors that exempt borrowers from reductions.
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
This document summarizes a presentation by William Skinner on new tax rules under the Tax Cuts and Jobs Act that impact individual owners of controlled foreign corporations (CFCs). Key changes include the introduction of a global minimum tax called GILTI on the foreign income of CFCs, which is currently taxed at ordinary rates to US shareholders. GILTI applies to the net income of CFCs in excess of a 10% return on depreciable tangible assets. The presentation provides examples of how GILTI is calculated and discusses the impact of making an election under Section 962 to be taxed at corporate rates on GILTI income. It also notes some advantages of GILTI for US corporate shareholders,
- The document provides instructions for filing an amended Illinois individual income tax return using Form IL-1040-X.
- It explains when an amended return should be filed, such as due to a change made on the federal return or an adjustment by the IRS.
- Detailed guidance is given on determining the filing deadline based on whether the change was state-only or resulted from federal adjustments. Supporting documentation that must be attached is also outlined.
This document compares International Financial Reporting Standards (IFRS) to relevant UK accounting standards. It notes several differences between the standards, including differences in the treatment of inventories, cash flow statements, accounting policies, revenue recognition, employee benefits, taxes, property, leases, impairments, and financial instruments. Adoption of IFRS would require changes to accounting policies and additional disclosures for many UK companies.
You’ve Received COVID-19 Related Federal Assistance – Now What?Citrin Cooperman
In this webinar, we discussed the complex web of audit and reporting considerations that organizations who received COVID-19 related federal assistance must consider as they approach year-end planning and look forward to 2021.
This document provides an overview of do-it-yourself 1040 tax preparation and filing. It defines key terms related to income, deductions, credits, and filing status. It reviews the various 1040 tax forms and schedules, and resources for filing including the IRS website. It outlines the process for completing a 1040 return including determining income and deductions, calculating taxes owed or refund amount, and electronic filing requirements. Overall, the document serves to educate taxpayers on completing their own 1040 tax return.
Solution Manual Advanced Accounting by Baker 9e Chapter 16Saskia Ahmad
Solution Manual, Advanced Accounting, Thomas E. King, Cynthia Jeffrey, Richard E. Baker, Valdean C. Lembke, Theodore Christensen, David Cottrell, Richard Baker, Advanced Financial Accounting, Advanced Financial Accounting by Baker Chapter 18, Advanced Financial Accounting by Baker Chapter 18 9th Edition, 9th Edition,
COVID-19 Update: Understanding the Provider Relief Fund for Dental ProvidersCitrin Cooperman
The document provides information for dental providers about the Provider Relief Fund, which was created by the CARES Act to provide financial assistance to healthcare providers responding to COVID-19. Key points include:
- There are important application deadlines of July 20 for Medicaid/CHIP funds and July 24 for dental provider funds.
- Dental providers must meet eligibility criteria to apply for targeted allocation funds by July 24, including not receiving other relief funds and providing patient care after January 31, 2020.
- Providers must manage funds properly by reviewing terms, establishing accounting and documentation, and preparing for reporting requirements to avoid potential recoupment of funds if expenses cannot be justified.
COVID-19 - How Staffing Companies Can Navigate the CrisisCitrin Cooperman
The document summarizes information from two webinars on how staffing companies can navigate the COVID-19 crisis. It discusses cash management strategies, borrowing options, staffing level considerations, and provisions from the Families First Act and CARES Act. Key points include cash forecasting, accessing lines of credit and government funding, determining optimal staffing levels, paid sick leave and family leave requirements, employer payroll tax deferrals and refundable employee retention credits.
CDD - December 2010 Interim Financial ReportBrad Sheahon
- Cardno Limited reported record profits for the half-year ended December 31, 2010, with profit after tax increasing 98% over the previous corresponding period to $31.7 million.
- Revenue for the period was $436 million, up 91% over the previous corresponding period, and operating cash flow increased 134% to $39.8 million.
- The company had a strong balance sheet with $80 million in cash and a low debt to equity ratio of 35% as of December 31, 2010.
The document summarizes 2010 cross-border tax updates for the US and Canada. On the US side, it discusses PFIC reporting requirements, foreign bank account reporting, tax rate changes including the healthcare bill, and the voluntary disclosure process. For Canada, it covers foreign tax credit generators, taxable Canadian property rule changes, tax avoidance transactions, and stock option changes. Quebec may serve as a model for federal tax changes.
The document discusses business succession planning and exit strategies for business owners. It covers creating buy-sell agreements to facilitate orderly transfers of ownership upon events like death, disability or retirement. It also addresses using ESOPs or estate plans to transfer ownership, as well as ensuring proper legal and tax structures are in place to protect the business assets and maximize value when transferring or selling the business. Key steps in closing a business are outlined, including required tax filings and legal entity dissolution documents at both the federal and state levels.
A Highlighted Analysis of Proposed Section 965 RegulationsCitrin Cooperman
This document summarizes key aspects of proposed regulations related to Section 965 of the tax code. Some highlights include:
- The definition of a specified foreign corporation and how ownership is determined.
- How accumulated post-1986 deferred foreign income is calculated, including reductions for distributions, foreign taxes, and deficits.
- Rules for determining a deferred foreign income corporation and earnings and profits deficit foreign corporation.
- How the aggregate foreign cash position is measured across multiple cash measurement dates.
- Rules around foreign tax credits, installment payments, acceleration events, and S corporation shareholder deferral elections.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
Solution Manual Advanced Accounting 9th Edition by Baker Chapter 14Saskia Ahmad
The document discusses SEC reporting requirements for public companies. It provides answers to multiple-choice questions covering topics such as the legal authority of the SEC, securities acts of 1933 and 1934, SEC forms like 10-K and 8-K, registration statements, and the Foreign Corrupt Practices Act. It also includes solutions to cases analyzing objectives of securities acts, roles of the SEC and FASB, information in proxy statements, and required disclosures in Form 10-Ks.
This document outlines the key documents needed for US expat tax preparation. It discusses providing a tax questionnaire, prior year's tax return, and travel calendar. It also details the documents needed for reporting income sources like wages, interest, dividends, stocks, real estate transactions, pensions, annuities, social security benefits, and other income. Finally, it discusses documents for deductions like interest and taxes paid, foreign housing expenses, dependents, and other deductions. It advises expat taxpayers to contact issuers if any tax documents seem to be missing.
Accounting for COVID-19 Funding for Post-Acute OrganizationsCitrin Cooperman
This document provides a summary of a webinar discussing various funding opportunities and tax provisions for healthcare organizations in response to the COVID-19 pandemic. It outlines programs like the Provider Relief Fund, Medicare accelerated payments, the Paycheck Protection Program, and tax credits for paid sick/family leave and employee retention. For each program, it discusses eligibility, allowable uses of funds, reporting requirements, repayment terms, and tax implications. The webinar aims to help organizations navigate relief options and ensure compliance to maximize available funding.
The document provides an overview of the 2003 Schools Workshop and guidance for auditing schools for the 2002-2003 fiscal year. Key points included changes to financial reporting requirements to comply with GASB 34, evaluating fundraising activities and the use of restricted funds, ensuring proper treatment of I-728 moneys, and current hot topics like the authority of districts to conduct general fund fundraising and the applicability of competitive bidding requirements. Auditors were instructed to focus on areas like enrollment trends, financial condition indicators, and the proper categorization of fund balance reserves and designations.
Solution Manual Advanced Financial Accounting by Baker 9th Edition Chapter 16Saskia Ahmad
Solution Manual, Advanced Accounting, Thomas E. King, Cynthia Jeffrey, Richard E. Baker, Valdean C. Lembke, Theodore Christensen, David Cottrell, Richard Baker, Advanced Financial Accounting, Advanced Financial Accounting by Baker Chapter 18, Advanced Financial Accounting by Baker Chapter 18 9th Edition, 9th Edition,
This document contains chapter 4 from an accounting textbook on consolidation of wholly owned subsidiaries. It includes questions and answers on consolidation topics such as:
- The purpose of eliminating entries in consolidation vs adjusting entries
- How differentials arise from acquisitions and how they are treated
- How a subsidiary's equity accounts are eliminated in consolidation
- How pushdown accounting can eliminate differentials
It also includes case studies on:
- Why consolidation is necessary to prepare consolidated financial statements
- Issues around presenting consolidated financial statements for a company with diverse subsidiaries
- Treatment of an unprofitable subsidiary in consolidation
- Assigning an acquisition differential to a subsidiary's assets and liabilities
- Implications of a subsidiary having negative
The document discusses additional consolidation reporting issues including:
- Cash flows from operations cannot be easily incorporated into the existing three-part workpaper format because both beginning and ending consolidated balance sheet totals are needed to determine cash flows for the period.
- Dividends paid to noncontrolling shareholders are included in the consolidated cash flow statement but not the consolidated retained earnings statement.
- The indirect method of preparing the statement of cash flows focuses on reconciling net income to cash flows from operations, but does not report explicit payments to suppliers.
- The document discusses partnership liquidation, including definitions, procedures, and accounting treatments.
- A simple partnership liquidation involves one cash distribution where partners receive amounts equal to their pre-distribution capital account balances.
- Priority rankings for distributing assets in liquidation are: 1) amounts owed to non-partner creditors and partners other than for capital and profits, and 2) amounts due to partners based on remaining assets after liabilities are paid.
Speeding Through 2020 Auto Webinar Series - What's Next for PPP?Citrin Cooperman
This document summarizes key information about the Paycheck Protection Program (PPP) loan forgiveness process.
It outlines the different forgiveness applications (3508S, 3508EZ, 3508), what they are used for, and the timeline for applying for forgiveness. It walks through the components of the 3508 application including documenting payroll costs, reductions to loan forgiveness amounts, and eligible non-payroll expenses. It also discusses recent developments like additional disclosure requirements and safe harbors that exempt borrowers from reductions.
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
This document summarizes a presentation by William Skinner on new tax rules under the Tax Cuts and Jobs Act that impact individual owners of controlled foreign corporations (CFCs). Key changes include the introduction of a global minimum tax called GILTI on the foreign income of CFCs, which is currently taxed at ordinary rates to US shareholders. GILTI applies to the net income of CFCs in excess of a 10% return on depreciable tangible assets. The presentation provides examples of how GILTI is calculated and discusses the impact of making an election under Section 962 to be taxed at corporate rates on GILTI income. It also notes some advantages of GILTI for US corporate shareholders,
- The document provides instructions for filing an amended Illinois individual income tax return using Form IL-1040-X.
- It explains when an amended return should be filed, such as due to a change made on the federal return or an adjustment by the IRS.
- Detailed guidance is given on determining the filing deadline based on whether the change was state-only or resulted from federal adjustments. Supporting documentation that must be attached is also outlined.
This document compares International Financial Reporting Standards (IFRS) to relevant UK accounting standards. It notes several differences between the standards, including differences in the treatment of inventories, cash flow statements, accounting policies, revenue recognition, employee benefits, taxes, property, leases, impairments, and financial instruments. Adoption of IFRS would require changes to accounting policies and additional disclosures for many UK companies.
You’ve Received COVID-19 Related Federal Assistance – Now What?Citrin Cooperman
In this webinar, we discussed the complex web of audit and reporting considerations that organizations who received COVID-19 related federal assistance must consider as they approach year-end planning and look forward to 2021.
This document provides an overview of do-it-yourself 1040 tax preparation and filing. It defines key terms related to income, deductions, credits, and filing status. It reviews the various 1040 tax forms and schedules, and resources for filing including the IRS website. It outlines the process for completing a 1040 return including determining income and deductions, calculating taxes owed or refund amount, and electronic filing requirements. Overall, the document serves to educate taxpayers on completing their own 1040 tax return.
Solution Manual Advanced Accounting by Baker 9e Chapter 16Saskia Ahmad
Solution Manual, Advanced Accounting, Thomas E. King, Cynthia Jeffrey, Richard E. Baker, Valdean C. Lembke, Theodore Christensen, David Cottrell, Richard Baker, Advanced Financial Accounting, Advanced Financial Accounting by Baker Chapter 18, Advanced Financial Accounting by Baker Chapter 18 9th Edition, 9th Edition,
COVID-19 Update: Understanding the Provider Relief Fund for Dental ProvidersCitrin Cooperman
The document provides information for dental providers about the Provider Relief Fund, which was created by the CARES Act to provide financial assistance to healthcare providers responding to COVID-19. Key points include:
- There are important application deadlines of July 20 for Medicaid/CHIP funds and July 24 for dental provider funds.
- Dental providers must meet eligibility criteria to apply for targeted allocation funds by July 24, including not receiving other relief funds and providing patient care after January 31, 2020.
- Providers must manage funds properly by reviewing terms, establishing accounting and documentation, and preparing for reporting requirements to avoid potential recoupment of funds if expenses cannot be justified.
COVID-19 - How Staffing Companies Can Navigate the CrisisCitrin Cooperman
The document summarizes information from two webinars on how staffing companies can navigate the COVID-19 crisis. It discusses cash management strategies, borrowing options, staffing level considerations, and provisions from the Families First Act and CARES Act. Key points include cash forecasting, accessing lines of credit and government funding, determining optimal staffing levels, paid sick leave and family leave requirements, employer payroll tax deferrals and refundable employee retention credits.
CDD - December 2010 Interim Financial ReportBrad Sheahon
- Cardno Limited reported record profits for the half-year ended December 31, 2010, with profit after tax increasing 98% over the previous corresponding period to $31.7 million.
- Revenue for the period was $436 million, up 91% over the previous corresponding period, and operating cash flow increased 134% to $39.8 million.
- The company had a strong balance sheet with $80 million in cash and a low debt to equity ratio of 35% as of December 31, 2010.
The document summarizes 2010 cross-border tax updates for the US and Canada. On the US side, it discusses PFIC reporting requirements, foreign bank account reporting, tax rate changes including the healthcare bill, and the voluntary disclosure process. For Canada, it covers foreign tax credit generators, taxable Canadian property rule changes, tax avoidance transactions, and stock option changes. Quebec may serve as a model for federal tax changes.
The document discusses business succession planning and exit strategies for business owners. It covers creating buy-sell agreements to facilitate orderly transfers of ownership upon events like death, disability or retirement. It also addresses using ESOPs or estate plans to transfer ownership, as well as ensuring proper legal and tax structures are in place to protect the business assets and maximize value when transferring or selling the business. Key steps in closing a business are outlined, including required tax filings and legal entity dissolution documents at both the federal and state levels.
Smart Strategies for Great Financial Mgmt.CherylBlack
The document summarizes a presentation on financial management strategies for nonprofits. It covers setting up accounting systems, annual budgeting and reporting cycles, differences between nonprofit and for-profit financial standards, and requirements for Form 990 tax filings. Major sections include achieving financial health, annual operating cycles, investment and cash management, and differences in financial reporting standards between nonprofits and for-profits.
Starting and maintaining a nonprofit organization in Florida requires multiple legal filings at both the state and federal level. At the state level, organizations must incorporate with the Florida Department of State, choosing a name, board members, and registered agent. The IRS application process involves proving public benefit, obtaining a federal EIN, and filing a lengthy Form 1023. Annual requirements include filing Form 990 with the IRS along with state renewals of the corporate filing and charitable solicitation registration. Maintaining compliance with all applicable laws is crucial for nonprofit status.
This document discusses taxation considerations for US citizen physicians practicing in Canada. It covers general US tax filing requirements, common Canadian tax structures such as holding shares individually or through a family trust and holding company, and planning considerations to avoid penalties and punitive taxation. Key structures include adding a spouse or family trust as shareholders and establishing a holding company to avoid controlled foreign corporation rules and passive foreign investment company income.
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
This document discusses various tax-related issues that may arise during and after a divorce, including:
1. Filing status options such as married filing separately, married filing jointly, and head of household for the divorce years.
2. Determining who can claim child dependents and adding language to the divorce agreement.
3. Innocent spouse rules and audit risks such as conflicting information between tax returns and divorce agreements.
4. Distinguishing distributions from flow-through entities versus compensation and reviewing K-1 forms.
5. Defining income for tax versus support purposes and ensuring all sources are reported.
The document summarizes IRS filing requirements for Form 990, 990-EZ, and 990-N for tax-exempt organizations based on annual gross receipts and total assets. It provides guidance on reporting compensation, functional expenses, fundraising activities, unrelated business income, and other requirements. Requirements vary depending on the tax year and level of annual receipts and assets. Failure to properly file can result in penalties.
The document provides an overview and summary of a presentation on smart strategies for great financial management for nonprofits. It discusses setting up accounting systems, the annual operating cycle including budgeting and financial reporting, differences between nonprofits and for-profits, and Form 990 tax reporting requirements. The major sections covered include achieving financial health, the annual operating cycle, investment and cash management, differences between nonprofits and for-profits, and Form 990 reporting.
The document discusses various aspects related to accounts, audit, and auditors under the Companies Act 2013. Some key points include:
- Every company must prepare annual financial statements including a balance sheet, profit and loss statement, cash flow statement and notes. The accounts must give a true and fair view of the company's affairs.
- The board of directors is responsible for the preparation of financial statements and a Directors' Responsibility Statement.
- An auditor must be appointed to audit the accounts annually and certify if they give a true and fair view. Their duties and qualifications are also outlined.
- The board report attached to financial statements must include details like number of board meetings, related party transactions, CSR
The document discusses the provisions related to accounts and auditors under the Companies Act 2013. It provides an overview of key sections regarding books of accounts, financial statements, board reports, appointment and rotation of auditors. It explains the requirements for listed and other prescribed class of companies. It also summarizes the eligibility, qualifications, disqualifications and duties of auditors. The document provides a high-level view of the accounting and auditing norms that companies need to comply with under the Companies Act.
Partner Training: Starting a NonprofitGrace Dunlap
This document provides an overview of the steps involved in starting a nonprofit organization, including establishing a board of directors, legal formation through filing articles of incorporation with the state, applying for 501(c)(3) federal tax exemption, complying with state-level regulations, and fulfilling annual reporting requirements. It discusses the services offered by CharityNet USA to help nonprofits with tasks such as document preparation, registrations, bookkeeping, and strategic planning. The conclusion emphasizes helping clients generate revenue and build a strong operational foundation through recommended services.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
Lime Corporation distributed $200,000 in cash to shareholder Orange Corporation and real estate worth $300,000 (adjusted basis of $20,000) and subject to a $100,000 mortgage to shareholder Gustavo. Despite banner profits in the current year, Lime had a retained earnings deficit. The distributions would be treated as a liquidating distribution for tax purposes, with consequences for Lime and the shareholders depending on earnings and profits.
This document discusses the accounting communication process and key players involved, including regulators, managers, directors, auditors, and financial statement users. It covers the roles and guidance these players receive, as well as common financial statements, reports, and disclosures used to communicate accounting information, such as annual reports, quarterly reports, and SEC filings. It also summarizes guidelines for ensuring useful financial reporting and analyzing company performance based on return on equity and its components.
The document discusses several hot topics for venture capital funds regarding US and foreign tax compliance and planning, including:
1) Recent US tax law changes affecting carried interest taxation and foreign bank account reporting.
2) Obama's proposals to tax carried interest as ordinary income and require self-employment taxes.
3) Considerations for structuring foreign subsidiaries and holdings to minimize tax liability, such as holding carried interest in an Israeli corporation.
4) Requirements and penalties for filing Form 5471 for foreign subsidiaries and Form TD F 90-22.1 for foreign bank accounts, and the implications for VC funds.
IRS Form 990 is an annual information return filed by most nonprofits and tax-exempt organizations. This includes organizations under Section 501(a), and certain political organizations and nonexempt charitable trusts.
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Cite Reporting The Results Of Foreign Operations Jan 2011
1. Council for International Tax Education (CITE)Reporting the Results of Foreign OperationsJanuary 24, 2011Randy Free, Partner, SoCal International Tax Practice Leader
2. Circular 230 Disclosure To ensure compliance with requirements imposed by the IRS, any U.S. federal tax advice contained in this document is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter that is contained in this document.
3. Reporting the Results of Foreign Operations Topics Obtaining the data from overseas for U.S. foreign informational forms Key issues in reviewing Form 5471 for foreign affiliates Computing earnings and profits – reconciliation with financial statement Other significant U.S. international reporting forms
4. Obtaining the data from overseas for U.S. foreign informational forms Identify sources of information Structural Information Financial data Include tax information request in financial statement “Reporting Package” Reorganizations Challenges Act early to overcome Failure to obtain
5. Structural Information Identify entities Critical because of penalties for failure to make the proper filings, Auditor's workpapers may ignore inactive companies for which no statutory financial statements are required Consult with the company's legal counsel for acquisitions or other changes Create and maintain a legal entity structure document that includes Full corporate name and address Country of incorporation Country of residence for tax purposes Corporate form, date of formation Capital structure and share ownership List of directors/officers Tax classification in country of tax residence (e.g., corporation, partnership, etc.) Classification for US tax purposes Function of each legal entity in the group
6. Financial Information needed Request early US GAAP income statement and balance sheet in local/functional currency Calculation of current and deferred income tax expense Local tax returns, with English translation, and supporting workpapers Receipts or other documentation supporting cash tax payments made Support for any foreign audit settlement Information about intercompany transactions including a description of the transaction, date entered into, payment made Transfer Pricing documentation report Information about changes in business and functions during the year. Best practice is to request as much of the tax compliance information as possible as part of financial reporting process to avoid multiple requests
7.
8. If information cannot be obtained in time to meet filing deadlines Try to avoid by starting early with clear comprehensive requests and explanations There is no official guidance Best practices would suggest: File your best information Prepare the forms to set the stage to request abatement of penalties due to reasonable cause Consider disclosure that forms are incomplete on their face, but were completed using the best information available Document in the files why incomplete and what was done to obtain the missing information Writing “information available on request” is an audit trigger
9. Key issues in reviewing Form 5471 for foreign affiliates Form 5471 – Top 10 Mistakes Not filed or filed incompletely Wrong filing category used Income statement: Tax instead of GAAP Balance sheet reported in functional currency E&P ignored – income statement replicated Subpart F income worksheets not completed Accumulated E&P categories not tracked Indirect transfer pricing information omitted Officer/shareholder information incomplete Duplicate filing not made
10. Risks of mistakes Penaltiesfor not filing or incomplete filing $ 10,000 for each failure to furnish the required information within time prescribed Additional $ 10,000 for each 30 day period or fraction thereof up to $ 50,000 if IRS has mailed a notice of failure and such information is not furnished within 90 days after such request Possible reduction in the foreign taxes available for deduction or as a foreign tax credits Automatic penalty if filed with delinquent Form 1120 HIRE Act holding statute open assessment statute not expired by March 18, 2010 Willful neglect
11. Know when Form 5471is required Filed for each Controlled Foreign Corporation ("CFC") More than 50% Level of US Ownership in vote OR value Filed by US shareholder (10% or more voting power) Categories of filers No longer applicable Officer or director of foreign corporation in which a US person has acquired 10% or more Acquisition or disposition of stock in a foreign corporation of 10% or greater ownership of ANY foreign corporation Control (more than 50%) of a foreign corporation for an uninterrupted 30 day period during the tax year – directly or indirectly US shareholder of a CFC on the last day of the CFC's year Exceptions Dormant CFC Multiple filers for same CFC
17. What’s the destination?Currently taxable amount of Subpart F Income limited to current E&P
18. What to look for: Investment in US property (Sec. 956) Income taxable to US Shareholder as a “deemed dividend” On Schedule F – Balance Sheet Loans to US shareholder Receivables from US shareholder or US affiliates Netting rule Prepare worksheet B Sec. 956 taxable amount NOTlimited to current E&P Quarterly average increase in investment in U.S. property by CFC
23. Computing earnings and profits – reconciliation with financial statement retained earnings Purpose for Controlled Foreign Corporations (CFC) Methods for E&P Adjustments When event requires computation Follows domestic concepts Annual and cumulative disclosure Maintain records Post-86 Pool Separate company Separate baskets Tier up when dividends distributed
24. Earnings and Profits Purpose : To determine taxable amount of distributions E&P represents a corporation's economic gains and losses, its capacity to distribute corporate earnings Different from both the accounting concept of net income and the corporation's taxable income E&P generally includes all income, expenses, gains and losses realized by the corporation E&P represents an increase or decrease in the amount of net assets of the corporation other than assets received from its shareholders as contributions to capital or distributions of assets to its shareholders
25. E&P Functional Currency Concept In 1981, Financial Accounting Standards No. 52 (FASB 52) introduced the “functional currency” approach, under which the currency of the economic environment in which a foreign entity operates is generally used as the unit of measure for exchange gains and losses Section 985(a) implements the functional currency concept and provides that “unless otherwise provided in regulations, all determinations under this subtitle must be made in the taxpayer's functional currency The adoption of, or the election to use a functional currency is a method of accounting, and any change in the functional currency is treated as a change in the taxpayer's method of accounting. Generally, the determination of the functional currency for a foreign entity will be obvious currency of the economic environment in which a significant part of the QBU's activities is conducted, provided the QBU keeps (or is presumed to keep under Reg. §1.985-1(c)(3)) books and records in that currency
27. E&P and tax “pools” E&P and foreign taxes are calculated annually, and accumulated in separate pools For the purpose of determining the tax of a shareholder of a foreign corporation, the earnings and profits of the corporation are maintained in the corporation's functional currency. These earnings and profits are translated into dollars at the appropriate exchange rate when they are actually distributed to the shareholder, or are deemed distributed to the shareholder in the case of the subpart F income of a controlled foreign corporation or gain treated as a dividend under Code Sec. 1248.(Code Sec. 986(b)(1)) In determining the amount of foreign taxes paid by a taxpayer under Code Sec. 901 or deemed paid by a domestic corporation shareholder in a foreign corporation under Code Sec. 902 and Code Sec. 960, a foreign income tax is translated into U.S. dollars using the exchange rate in effect as of the time the current income taxes are accrued. (Code Sec. 986(a)(2)(A))
28. E&P of a CFC must be categorized into baskets, pools, and layers, and characterized by source The identification of E&P by categories is required to determine the following: Foreign tax credit basket classification of dividends US or foreign source of the dividend Taxability of actual distributions as dividends Amount of exchange gains or losses on distributions of PTI and the appropriate foreign tax credit basket classification Information required for reporting purposes Deemed-paid foreign tax credit Taxability of deemed dividends under the Subpart F income and investments of earnings in U.S. property rules Dividend recharacterization resulting from the sale or exchange of a CFC's stock Addition or attribution of E&P with respect to transactions under §367 E&P adjustments to the stock basis of a CFC for interest expense allocation purposes at the US shareholder level
29. E&P Adjustments Required for CFCs Code Sec. 964 E&P determined using rules similar to those applicable to domestic corporations Illegal bribes, kickbacks or other payments (as defined under the Foreign Corrupt Practices Act of 1977) may not be taken into account Steps to determine the earnings and profits of a CFC: A profit and loss statement must be prepared for a tax year from the books of account regularly maintained by the foreign corporation for the purposes of accounting to its shareholders Adjust for material items to conform the statement to US accounting principles the accounting principles to be applied are those generally accepted in the United States to reflect in the financial statement of a domestic corporation the operations of its foreign affiliates: clear reflection of income physical assets be taken into account at historical cost no systematic undervaluation of assets or overvaluation of liabilities income and expense taken into account without regard to equalization over more than one accounting period Adjust for tax accounting standards, with allowable elections
30. E&P Adjustments Required Elections by CFC An election or to adopt a taxable year or method of accounting shall not be required until the due date (including extensions) of the return for a controlling domestic shareholder's first taxable year with or within which ends the foreign corporation's first taxable year in which the computation of its E&P is significant for US tax purposes with respect to its controlling domestic shareholders When “significant”? Filing a Form 5471 is not a significant event For taxable years beginning after April 25, 2006, significant events include: A distribution from the foreign corporation to its shareholders with respect to their stock. An amount is includible in gross income with respect to such corporation under section 951(a). An amount is excluded from subpart F income of the foreign corporation or another foreign corporation by reason of section 952(c). Any event making the foreign corporation subject to tax under section 882. The use by the foreign corporation's controlling domestic shareholders of the tax book value (or alternative tax book value) method of allocating interest expense under section 864(e)(4). A sale or exchange of the foreign corporation's stock of the controlling domestic shareholders that results in the recharacterization of gain under section 1248.
31.
32. Form 8865 Report of U.S. Persons With Respect to Certain Foreign Partnerships
33. Form 8858 Information Return of US Persons With Respect to Foreign Disregarded Entities
34. Form 926 Report by a U.S. Transferor of Property to a Foreign Corporation
35. Form 8838 Consent to Extend the Time to Assess Tax Under Section 367 - Gain Recognition Agreement
36. Form 8621 Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund
39. Form 8865Report of U.S. Persons With Respect to Certain Foreign Partnerships Purpose: To report information required under Sec 6038 - controlled foreign partnerships (CFP) Sec 6038B - transfers to foreign partnerships Sec 6046A - acquisitions, dispositions, and changes in foreign partnership interests Controlled Foreign Partnerships Where US persons, at any time during the partnership’s tax year end, possess a 10% or greater ownership interest (in either capital, profits, deductions or losses), including constructive ownership, where these US persons own more than a 50% interest in the foreign partnership A U.S. person is defined under Code Section 7701(a)(30) as a U.S. citizen or resident, a domestic partnership, a domestic corporation, and any estate or trust that is not foreign.
40.
41. Description of the property transferred including the type of property and date of transfer
42.
43. Form 8858 Information Return of US Persons With Respect to Foreign Disregarded Entities
44.
45.
46. If the FDE is owned directly or indirectly by a domestic corporation and the foreign disregarded entity incurred a net operating loss for the taxable year, is the FDE a “separate unit” as defined under the dual consolidated loss rules?
47.
48. The tax rules for translating currency gains and losses are based on principles completely different from GAAP
49. Currency gain and loss is not recognized for tax purposes until there has been a “remittance” from a branch with a different functional currency.
55. Transfers in a liquidation of a US corporation into a foreign parent under §332
56. Transfers to a foreign corporation in a tax-free reorganization, under §354, §356, or §361 (including certain deemed transfers)
57. Transfer of a foreign corporation in a tax-free spinoff, etc., under §355 — regardless, in some cases, of whether the transferee is a foreign corporation
59. The US persons holds directly or indirectly at least 10% of the total voting power or value of the foreign corporation
60. OR the amount of cash transferred by the US person ion during the 12-month entity and the income exceeds $100,000Transfers by a partnership must be filed by the partner Penalty for failure to file 10% of the fair market value of the transferred property Form 926 Report by a U.S. Transferor of Property to a Foreign Corporation
61.
62. Identifying information about the transferor, (including identification of its controlling shareholders, if the transferor is a corporation that went out of existence, e.g., in a split-up or liquidation)
63. If the actual transfer was performed by a partnership, and the person filing the return is one of the partners, the partnership also must be identified
65. Identifying information about the transferee, including whether it is a controlled foreign corporation and how it is characterized (e.g., as a partnership or corporation) under foreign law.
67. Information about the transfer itself. This includes the date, the type of transfer under U.S. law (e.g., §351 transfer to controlled subsidiary, §332 liquidation), a description of the transferred property, whether the transfer was the result of a “check-the-box” entity classification election, and whether any intangible property was transferred (and if so, a description of the rights transferred). In certain cases under §367(a), a person transferring property to a foreign corporation must include amounts in incomeSupplemental information also must be attached, as summarized in the Instructions, and described in far more detail in the regulations.
68.
69.
70. Form 8621 Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund Any level of ownership in a "PFIC" Direct or indirect A foreign corporation is a PFIC if: 75% or more of its gross income constitutes “passive income” or 50% or more of its assets produce, or are held for the production of, passive income. Once a PFIC, always a PFIC US persons who hold stock in a PFIC are subject to an adverse tax regime with respect to “excess distributions” from a PFIC, which includes gain on the disposition of stock of a PFIC, including a pledge of its stock. Excess distribution is taxable at highest marginal rate, pro rata over holding period of shares, plus an interest charge. To QEF or not to QEF To report ordinary income and capital gains currently (similar to a US mutual fund). Shareholder information statement from PFIC Timing is key to the pedigree
71. Form 8621Procedures Filed with tax return of shareholder A separate form is filed for each PFIC. Not required for US shareholder if PFIC is also a CFC. Elections generally made by first US person in chain of ownership QEF election Deemed sale election Deemed dividend election Extend the time to pay the tax for QEF Mark-to-Market election
72. Form 5713 International Boycott Report Filed by US person to report Operations in or related to "boycotting countries" Receipt of boycott requests or agreements made Participation in boycott may result in loss of tax benefits Foreign tax credit CFC deferral Filed in duplicate With US person's income tax return To IRS in Philadelphia Penalties for willful failure to file $25,000 fine Imprisonment up to one year Both
73. Form 5713Boycotting Countries List updated by Treasury Kuwait Lebanon Libya Qatar Saudi Arabia Syria United Arab Emirates Yemen Any other country that requires participation in an international boycott per Sec 999(a)(3)
74. Form TDF 90-22.1 Report of Foreign Bank and Financial Accounts Annual filing by each US Person with a financial interest in or signature authority or other authority Any financial account ( bank, securities, etc.) in a foreign country and The aggregate value exceeds $10,000 at any time during the tax year Due June 30th No extensions Sent to Department of the Treasury
75. Form TDF 90-22.1 U.S. "Ownership" Financial interest includes: Owner of record or legal title Acting as agent, nominee, attorney or other capacity on behalf of US Person Entity in which the US person owns directly or indirectly 50% or more of total value Signature or Other Authority Over an Account Control the disposition of money or other property by delivery of a document with signature to the bank or other institution.
77. Contact Information Randy Free Partner – SoCal International Tax Practice Leader Grant Thornton LLP 18400 Von Karman Ave, Suite 900 Irvine, California 92612 949.608.5311 (office) 949.606.6859 (cell) Randy.Free@US.gt.com
78. Tax Professional Standards StatementThis document supports Grant Thornton LLP’s marketing of professional services, and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the subject of this document we encourage you to contact us or an independent tax advisor to discuss the potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this document may be considered to contain written tax advice, any written advice contained in, forwarded with, or attached to this document is not intended by Grant Thornton to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.
Editor's Notes
It is imperative that the data for calculating E&P is gathered on a yearly basis. Important data and possibly foreign income tax returns may be discarded by the foreign corporation once the foreign country's tax statute of limitations lapses. In addition, the IRS will most likely require the documentation upon audit. If the data is not gathered currently it may be difficult if not impossible to subsequently obtain.
A CFC (Controlled Foreign Corporation) is defined in §957 as foreign corporation with U.S. Shareholders that own (directly, indirectly or constructively, within the meaning of sections 958(a) and (b), on any day of the tax year of the foreign corporation, more than 50% of:The total combined VOTING power of all classes of its voting stock; ORThe total VALUE of the stock of the corporation. In determining ownership, the attribution rules of §318 apply, however, the 50% ownership attribution is reduced to 10% by §6038(e)(2)(B).
Units of functional currency that equal USD 118.0532 Yen to 1 USD
Participation in, or cooperation with, an international boycott occurs when a person, in order to do business in one country, agrees not to do business with a specified country or with other companies doing business in specified countries. An agreement not to hire employees or do business with other companies whose employees are of a specified nationality, race or religion also constitutes boycott activity.