This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
This presentation will be two hours in duration and will offer two CPE credits. The presentation will focus on tax law updates for both businesses and individuals that are expected to be passed. The discussion during the webinar will feature information on both sides, as they are often interdependent.
The webinar will also touch on the tax policies of some of the 2016 presidential candidates and how these policies will impact you and your organization.
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
This presentation will be two hours in duration and will offer two CPE credits. The presentation will focus on tax law updates for both businesses and individuals that are expected to be passed. The discussion during the webinar will feature information on both sides, as they are often interdependent.
The webinar will also touch on the tax policies of some of the 2016 presidential candidates and how these policies will impact you and your organization.
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
Tax Planning Update by Tracy Monroe, CPA. Presented at Cohen & Company's Client CPE Day. Covers business as well as individual tax updates.
www.cohencpa.com
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During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
This WEBINAR is an overview about how the Tax Cuts and Jobs Act alters the U.S. tax code for individuals and businesses.
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Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
Join us for a conversation about how tax reform impacts individuals and businesses, including corporations and pass through entities.
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in Philadelphia to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies. Join us to get answers to questions in the following areas:
Corporate and Businesses
Pass-Through Entities
International Issues
Individuals
איל הורוביץ הוא אדם קשוב-פירוט ובעל רמה גבוהה של דיוק. תכנון המס מאפשרת יצירת citizento את השימוש הטוב ביותר של מספר ממס, הטבות ובקפוצ'ינו להורדת המס שלהם, האחריות מעל לשנה פיננסית.
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This presentation reviews key considerations in tax reform – balancing revenues, growth, and tax equity.
Charts describe the current tax system, its general framework, progressive structure, complexity, biases, and distorting features.
It also explores who pays taxes, and how markets shift the tax burden.
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This lecture explores how the consequences of policy options can be determined and why they should guide the reform effort. The Tax Foundation's Taxes and Growth Dynamic Tax Model will be demonstrated.
Also discussed: the benefits and limitations of dynamic vs. static analysis and scoring of tax changes, which tax features harm growth the most, which potential reforms help the most, and which revenue offsets hurt the least. Differing views of how to predict the effects of tax changes on economic growth, how different models view the effect of the federal budget deficit and the Federal Reserve on the outcomes, and the proper role of monetary policy.
Register for Tax Foundation University Online here: https://taxfoundation.org/tax-foundation-university-remote/#enroll
In this Forbes Bankable webinar, tax attorney and Forbes senior editor Kelly Erb offers the tips and tools that you need to make tax season a lot less painful.
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- Facts of the Case
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- Supreme Court’s Verdict
- Key Learnings and Way Forward
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www.cohencpa.com
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Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
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For more in-depth information and personal engagement with our team, we welcome you to join us on Tuesday, January 30th from 9-11am at our Rockville Location, 1445 Research Boulevard, Ground Level Conference Room, Rockville, MD 20850.
Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
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The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in Philadelphia to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies. Join us to get answers to questions in the following areas:
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איל הורוביץ הוא אדם קשוב-פירוט ובעל רמה גבוהה של דיוק. תכנון המס מאפשרת יצירת citizento את השימוש הטוב ביותר של מספר ממס, הטבות ובקפוצ'ינו להורדת המס שלהם, האחריות מעל לשנה פיננסית.
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It also explores who pays taxes, and how markets shift the tax burden.
Tax Foundation University 2017, Part 3: Modeling Tax Changes — Which Help, Wh...Tax Foundation
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Register for Tax Foundation University Online here: https://taxfoundation.org/tax-foundation-university-remote/#enroll
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Ted Ginsburg, CPA, JD from Skoda Minotti's Employee Benefits group provides an update on the Affordable Care Act (ACA) for employers who were not subject to it in 2015, but are facing IRS filing requirements moving forward.
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This popular session returns in 2015 with 12 new great ideas. There are a number of incentives out there for companies and individuals alike that, unless you are looking specifically for them, they may be overlooked.
Topics Include:
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What governmental income tax agencies are doing to try to stop income tax refund fraud
Other income tax-related frauds to be aware of this time of year
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This presentation provides an update on both recently issued and forthcoming pronouncements of the Financial Accounting Standards Board (FASB). Through this presentation, you should be able to identify what changes are effective for your 2015 financial statements, including changes you may choose to early adopt.
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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!
Current Tax Planning Techniques in U.S. and International TransactionsWinston & Strawn LLP
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Introduction to Taxation of Foreign Investment in U.S. Real EstateSmart Accountants
This webinar introduces some of the most important tax issues that non-US investors in U.S. real estate should consider.
You will learn:
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- FDAP income (Not trade or business income)
- Effectively Connected Income (ECI)
- Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)
- Choice of proper investment structure and tax planning
- Tax Implications for:- Rental income tax- Capital Gain Tax on the eventual disposition of property- Estate/Gift tax consequences
- Other consideration- Anonymity – Nondisclosure of the identity- Assets protection- The simplicity of the structure balances against complexity costs.
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!
Numerous US individuals own overseas assets or have an interest in them. The IRS may penalize these taxpayers if they fail to report these assets on their tax filings. Consequently, the streamlined filing compliance procedure exists to assist these individuals with:
– A streamlined process to file delinquent or amended tax returns;
– Resolving tax and penalty procedures for filing delinquent or amended returns; and
– Resolving penalty and tax obligations
This webinar will guide you through the complexities of Streamlined Filing Compliance Procedures and make your US Tax Journey Exponentially easier!
Takeaways:
Topics that we will cover in the upcoming webinar:
1. Introduction to Streamlined filing
2. Eligibility Criteria for Streamlined Filing
3. Types of Streamlined Filing
– Streamlined Foreign Offshore Procedures
– Streamlined Domestic Procedures
4. Other rules and regulations
5. FAQs, and much more
Who Attended?
- US Citizens Living in the US and Outside
- CPAs, EAs, CAs, ACCAs
- Tax and Accounting Professionals with US Citizens as their clients
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
International Tax Reform - Tax Cuts and Jobs Act of 2017gppcpa
This presentation is an overview of the new tax law and how it impacts international taxation including such topics as the Participation Exemption, Transition Tax, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, Base Erosion and Anti-Abuse Tax, and Interest Deductibility.
When it comes to getting your clients to the United States you’re the master. But what happens when that conversation turns to the client’s financial planning? Global migration can lead to some tricky tax situations which may not always get the attention they deserve. In this webinar, senior accountants from Moss Adams LLP will address some tax issues that every immigration lawyer should be aware of.
In this presentation, our speakers will discuss planning for entry into the U.S. tax system, including a high-level overview of income, and estate and gift tax considerations. We will address the U.S. foreign disclosure rules and the US anti-deferral regimes. And we will briefly touch on tax planning prior to the surrender of U.S. citizenship or long-term permanent resident status.
Estate and Gift Tax Issues.
Planning for move to U.S.
Estate/gift tax residency.
Estate/gift tax applicability for NRA’s and for U.S. residents.
Planning for U.S. gift/estate tax applicability – considerations of trusts/gifting before a move.
Planning for the U.S. foreign disclosure rules – streamlining/consolidation of foreign assets/entities before a move.
Considerations Prior to moving to U.S.
Considerations related to negotiating compensation arrangements/benefits/tax equalization agreements/etc. before moving to the U.S.
Determining taxation and differences of taxation for U.S. residents vs. non-residents.
U.S./State taxation of foreign nationals.
U.S. residency vs non-residency for income tax purposes.
U.S. taxation of U.S. persons vs NRAs.
Substantial Presence Test.
Closer Connection Exception.
Dual Status Returns.
First Year Elections.
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations. While enacted to rationalize the taxation of U.S.-based multinational corporations, these rules have an even more dramatic effect on non-corporate U.S. shareholders of controlled foreign corporations, such as individuals, trusts, S corporations and partnerships. These slides, which were originally presented as part of a Strafford group webinar, provide an overview of GILTI as applied to a non-corporate U.S. shareholder, interaction with Section 962, and review of other international tax reform changes relevant to individual shareholders in foreign businesses.
Key Takeaways:
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- Controlled Foreign Corporation
- Base Erosion and Anti-Abuse Tax
- Covid Impact and Measures
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4. 4
JURISDICTION TO TAX
Source Jurisdiction
• Residents and nonresidents alike
are taxed on income from
economic activity within a
particular (sourced) country
Residence Jurisdiction
• All income accruing to
residents of a country,
regardless of source, is subject
to tax by that country
5. 5
STATUTORY FRAMEWORK
Who is a U.S. Person?
• U.S. citizens
• Green card holders (lawful
permanent residents)
• Residents for income tax purposes
“Substantial presence” test
– Generally, 31 current days, plus 183 days in
current and prior two years
• Domestic corporation / partnership /
estate / trust
Based on place of incorporation /
organization – U.S. state
6. 6
STATUTORY FRAMEWORK
Who is a Foreign Person?
• Anyone who is not a U.S. person
Non-U.S. citizen
Non-green card holder
Does not satisfy “substantial presence test”
• Foreign corporation / partnership
(organized outside the U.S.)
• Foreign estate/trust
• Foreign government
7. 7
STATUTORY FRAMEWORK
U.S. Persons
• What income is taxed?
U.S. person is taxed on worldwide income wherever sourced
Does not matter where U.S. citizen lives
• How is income taxed?
Net taxable income
Progressive rates
Double taxation avoidance
Foreign tax credit (or deduction)
8. 8
STATUTORY FRAMEWORK
Foreign Persons
• What income is taxed?
U.S.-sourced income that is:
– “ECI” — income “effectively connected” with
U.S. “trade or business”
– “FDAP” — “fixed, determinable, annual, or
periodic gains, profits, and income”
– Interest, dividends, rents, royalties, wages,
salary
– Gain on sale of U.S. real property
9. 9
U.S. TAX DEFERRAL
• U.S. shareholders of nonresident corporations are not subject
to U.S. taxation until distributions are received from the
corporation as a dividend
• Deferral benefit is the greatest when foreign tax on income of
the foreign corporation is low or none
10. 10
ANTI-DEFERRAL REGIMES
U.S. shareholders might be subject to U.S. tax even if income is
not actually distributed by the FC to the shareholder
• Foreign corporations
Controlled Foreign Corporation (CFC) — Subpart F Income
– U.S. control required
Passive Foreign Investment Company (PFIC)
– Income Test: 75% or more of gross income is passive
– Asset Test: 50% or more of a corporation’s assets are passive
– U.S. control NOT required
11. 11
FOREIGN CORPORATIONS
CONTROLLED
Definition
• A foreign corporation in which:
More than 50% either
– Total combined voting power of all classes of
stock entitled to vote, or
– Total value of the stock
Is owned by U.S. shareholders
On any day of the foreign corporation’s
taxable year
13. 13
SUBPART F
• Designed to prevent deferral of portable income
• Directed at two basic types of income:
Passive investment income
Income derived from dealings with related entities
• Applies to income derived by a CFC and is not country-specific
• Eligible for foreign tax credit
14. 14
SUBPART F
• Subpart F – income is included in income of U.S. shareholder
in year earned rather than when distributed
• §956 Income – earnings of CFC invested in U.S. property
treated as distribution
Includes most loans to U.S. shareholders
Applies when U.S. shareholder pledges stock as loan security
• Basis in CFC stock is adjusted for inclusion and distributions
• Not considered dividends, so not eligible for reduced
“qualified” tax rate or DRD deduction
15. 15
PREVIOUSLY TAXED INCOME
SUBPART F:
• Prevents double taxation that could occur upon an actual
distribution from a CFC
• Excludes from gross income any actual distributions of
earnings previously taxed as Subpart F income or
investments in U.S. property
• Foreign exchange gain or loss is recognized when actual
distribution occurs
17. 17
PERMANENT ESTABLISHMENT
Taxation of Business Profits
General treaty rule:
Profits of a foreign corporation from
U.S. activities are taxable if it carries
on business in the U.S. through a
permanent establishment (PE). If
so, the profits may be taxed by the
U.S., but only to the extent they are
attributable to that PE.
18. 18
PERMANENT ESTABLISHMENT
PE – Specific Inclusions, U.S. Model, Article 5
• PE includes:
Place of management, branch office, factory or workshop
Place where natural resources are extracted (e.g., mine, oil or gas well,
quarry)
Building site, construction or installation project that lasts longer than 12
months
Drilling rig or ship used to explore for natural resources if that activity
lasts longer than 12 months
19. 19
PERMANENT ESTABLISHMENT
PE – Specific Inclusions, U.S. Model, Article 5
• PE does not include:
Use of facilities solely to store, display or deliver goods belonging to enterprise
Maintenance of a stock of goods solely for purpose of storage, display, delivery
or processing by another enterprise
Maintenance of a fixed place of business solely to purchase goods or collect
information
Maintenance of a fixed place of business solely for the purposes of carrying out
other activity of a “preparatory or auxiliary” nature (e.g., advertising)
21. 21
FOREIGN TAX CREDIT BASICS
• The purpose of the Foreign Tax Credit is to mitigate double
taxation
Foreign income taxed at the higher U.S. or non-U.S. tax rate
• The foreign tax credit is generally available to:
U.S. citizens
Domestic corporations
22. 22
FOREIGN TAX CREDIT BASICS
• The Foreign Tax Credit is elective
Taxpayers can choose on an annual basis to either claim the foreign tax
credit or claim a tax deduction for foreign taxed paid
• In any given tax year, taxpayers must either credit or
deduct all foreign taxes
No partial credit and partial deductions permitted in the same tax year
23. 23
FOREIGN TAX CREDIT BASICS
What taxes are credible?
• Only income or excess profits taxes (essentially income
taxes) are credible
• Tax must resemble U.S. income tax (Reg. § 1.901-2)
• Penalties, fines, interest, custom duties, VAT, capital and
asset taxes do not qualify for the credit
• Tax payment must also be compulsory to be credible for U.S.
federal tax purposes
• During compliance process, foreign tax returns should be
requested and maintained in order to support the foreign tax
credit claimed upon audit
24. 24
SEPARATE BASKETS
FOREIGN TAX CREDIT LIMITATION:
• Under IRC § 904(d), the credit limitation must be
determined separately for foreign taxes on each
separate limitation category (basket)
• For taxable years beginning after December 31, 2006,
there are only two baskets:
General category income
Passive category income
25. 25
MISCELLANEOUS ITEMS
FOREIGN TAX CREDIT:
• Excess foreign tax credits can be carried backwards and
forward
One-year carry-back
10-year carry-forward
• AMT foreign tax credit calculated separately
26. 26
DCT FOREIGN TAX CREDITS
§902
• Withholding – tax deemed paid by income recipient even
though payment could be made by withholding agent
• Income tax on compensation
• Income tax paid on business profits of flow-through entity
(e.g., branch, partnership)
27. 27
TAX CREDIT
INDIRECT FOREIGN
(“Deemed Paid Credit”) - §901
• What taxes are credible?
• Income taxes paid by foreign corporations
• Who is eligible to take the credit on their U.S. tax return?
• Allowed to certain domestic corporations (10% ownership
requirement)
• Not allowed for individuals, partnerships or S corporations
• Allows for indirect foreign tax credit on dividends received
from foreign corporations, although tax is paid by the foreign
corporation, not the recipient
28. 28
TAX CREDIT
INDIRECT FOREIGN
(“Deemed Paid Credit”) - §902
• Calculation of Deemed Paid Credit:
Dividend income received deemed to
have foreign taxes repatriated with it
Determine the amount of a distributing
corporation’s pre-tax earnings attributable
to the dividend (IRC §78 “gross up”)
Tax “pre-tax” earnings and allow credit
31. 31
FORM 5471/8865/8858
When and Where to File?
• Form 5471/8865/8858 is attached to the taxpayer’s income tax return and
is due when the income tax return is due, including extensions
• Type of form to be prepared:
Foreign corporation Form 5471
Foreign partnership Form 8865
Foreign disregarded entity Form 8858
32. 32
• A $10,000 penalty is imposed for each annual
accounting period of each foreign corporation for
failure to furnish the required information within the
time prescribed
If the information is not filed within 90 days after the IRS has mailed a
notice of the failure to the U.S. person, an additional $10,000 penalty
(per foreign corporation) is charged for each 30-day period, or fraction
thereof, during which the failure continues after the 90-day period has
expired up to a maximum of an additional $50,000 penalty
FORM 5471/8865/8858
PENALTIES
34. 34
OVERVIEW
• Increased global scrutiny of related party transactions
• Transfer pricing regulations and penalties vary by country, as
well as documentation requirements
• Three branches of transfer pricing to reduce intercompany
transaction exposures and risks:
Documentation / compliance
Planning
Controversy
35. 35
AUDIT TRIGGERS
• Certain intercompany Transactions:
Intangible property (e.g., technology,
patents, know-how)
Services (e.g., management,
engineering, G&A)
• Cost sharing arrangements (CSA)
• Losses earned for consecutive
years
36. 36
PRICING STRATEGIES
TRANSFER
Documentation
• First line of defense under audit
• Documentation rules vary by country
• Requirements, filing deadlines, language, method selection,
accepted comparable companies / transactions, etc.
• In general, reports will contain:
Industry analysis
Functional analysis (i.e., a detailed narrative of a company’s functions, assets
and risks)
Economic analysis (i.e., a method used to test transaction, pertinent regulations
and benchmarking results
37. 37
PRICING STRATEGIES
TRANSFER
Compliance
• In the U.S., taxpayers:
Must file Forms 5471 and 5472 for related party
transactions
May need to file Form 8275 for disclosure
Must report Uncertain Tax Positions (UTP) on
Schedule UTP
– Includes description of transaction and size of
associated reserve
– FIN48 documentation
40. 40
ACCOUNT (FBAR) — FinCEN
FOREIGN BANK
• Individuals and entities with a financial interest in or
signature authority over foreign accounts
• Must report via Form 114, if aggregate value in
foreign accounts exceeds $10,000
• Significant penalties can apply
41. 41
ACCOUNT (FBAR) — FinCEN
FOREIGN BANK
• New enacted due dates for Form 114
• For tax years beginning after December 31, 2015
Form 114 will be due April 15
Maximum extension for a six-month period ending October 15