International Tax Articles
Posted by Amanda Mooney on June 07, 2022
When President Biden assumed office on January 20, 2021, he inherited the tariffs the previous Administration levied on imports of most products from China based on the United States Trade Representative’s (USTR) investigation of China’s practices related to Technology Transfer, Intellectual Property, and Innovation. These duties, known as the Section 301 tariffs, were implemented in four tranches beginning in July 2018 and cover more than $300 billion of Chinese products. Because of the broad range of merchandise impacted by the tariffs, USTR initiated an exclusion process that allowed interested parties to petition for an exemption from the Section 301 tariff increases for specific imports classified within a given Harmonized Tariff Schedule of the United States (HTSUS) subheading.
Posted by Amanda Mooney on February 01, 2021
On January 5, 2021, Treasury and the IRS issued an early version of final regulations that provide additional guidance regarding the limitation on the deduction for business interest expense under Section 163(j). Among many other items, these regulations address the application of the limitation with respect to controlled foreign corporations (CFCs).
Posted by Angela Miles on January 28, 2021
The following guide includes many of the most important 2021 federal tax amounts including capital gain tax rates, standard mileage rates, estate and trust income tax rates, and itemized deduction limits.
Posted by Amanda Mooney on October 22, 2020
On September 29, 2020, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) released an early version of final regulations (the 2020 FTC final regulations) for publication in the Federal Register.
Posted by Mark Janulewicz on August 10, 2020
On July 28, 2020, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) released final regulations under Section 163(j).
Posted by Amanda Mooney on April 24, 2020
At the request of concerned countries, the OECD Secretariat issued the guidance based on a careful analysis of the international tax treaty rules. The analysis addresses concerns as a result of the novel coronavirus (COVID-19) pandemic related to the creation of a permanent establishment (PE), the residence status of a company (place of effective management), cross border workers, and a change to the residence status of individuals.
Posted by Mark Janulewicz on April 21, 2020
Volatility created by the COVID-19 pandemic has had an immediate impact on many U.S. taxpayers conducting business abroad. Due to liquidity and cash flow needs, such U.S. taxpayers may need to repatriate cash from their foreign operations. This alert discusses some key international tax issues that taxpayers may need to consider when repatriating cash from their foreign operations.
Posted by Cory Van Deusen V on June 14, 2019
On April 17, 2019, the IRS and Treasury issued its much anticipated second set of proposed regulations under Internal Revenue Code, Section 1400Z-2, Special rules for capital gains invested in opportunity zones.
Posted by Sherry DelleBovi, Michael Grimaldi, Mark Janulewicz, Brian Kern, Michē Needham, David Schlein, Cory Van Deusen V on January 03, 2019
Business tax planning is very complex. Careful planning involves more than just focusing on lowering taxes for the current and future years. How each potential tax saving opportunity affects the entire business must also be considered.