International Tax Articles

This guide examines international tax planning circumstances, foreign tax credit considerations, and more as businesses plan for the year end and the coming year.

The Biden administration has released its budget proposal for fiscal year 2024. The proposal aims to decrease the federal deficit by roughly $3 trillion within the next decade. To achieve this, taxes will be raised on high-net-worth individuals and large corporations.

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.

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).

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.

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.

On July 28, 2020, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) released final regulations under Section 163(j).

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.

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.

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