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International Tax Articles

 

International Aspects of 2021 Final Regulations on Deduction of Business Interest Expense

International Aspects of 2021 Final Regulations on Deduction of Business Interest Expense

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).

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2021 Federal Tax Rates Quick-Reference Guide

2021 Federal Tax Rates Quick-Reference Guide

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.

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Treasury Releases Foreign Tax Credit Regulations

Treasury Releases Foreign Tax Credit Regulations

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.

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International Aspects of the 2020 Section 163(J) Proposed Regulations

International Aspects of the 2020 Section 163(J) Proposed Regulations

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).

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OECD Issues Statement on International Double Tax Conventions Relating to the COVID-19 Crisis

OECD Issues Statement on International Double Tax Conventions Relating to the COVID-19 Crisis

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.

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International Tax Considerations Relating to Repatriation in Light of COVID-19

International Tax Considerations Relating to Repatriation in Light of COVID-19

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.

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Navigating a Global Expansion

Navigating a Global Expansion

Posted by Amanda Mooney on September 02, 2019

Is your business part of the global economy? If not, it may be losing out on some revenue- and value-building opportunities.

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IRS and Treasury Release Second Set of Opportunity Zone Guidance

IRS and Treasury Release Second Set of Opportunity Zone Guidance

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. 

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2018 Year-End Tax Planning for Businesses

2018 Year-End Tax Planning for Businesses

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.

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Watch Out for these Tax Issues When Planning for Your Business in 2018

Watch Out for these Tax Issues When Planning for Your Business in 2018

Posted by Cory Van Deusen V on August 14, 2018

The Tax Cuts and Jobs Act makes sweeping changes, but some of the new provisions won't necessarily be relevant to your situation. Here's a quick reference guide to the major changes under the new law to help you understand what's changing.

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