Trump's Plan - International Highlights


While the Trump tax plan, as presently disclosed, has a number of big picture features aimed at lowering tax rates and broadening the tax base, it is short on details. This is particularly true when it comes to matters involving multinational taxpayers or cross-border transactions.

The one provision directly affecting U.S. international tax considerations which has been announced is a proposal for a deemed repatriation of currently deferred profits of U.S. multinational corporations from their subsidiaries at a tax rate of ten percent. As with other provisions, details have not been pro...

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U.S. Treatment of Tax Credits in French Accord Questioned

According to tax practitioners, the IRS is taking advantage of taxpayers and their inability to claim foreign tax credits on income earned while living abroad in France, despite the agency not being able to show the official French position on the applicable totalization agreement.

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Final Rules Govern U.S. Country-By-Country Reporting

New regulations for MNE (multinational enterprise) groups with revenues of $850 million or more were issued by the IRS in order to prevent such companies from shifting profits to low or no tax jurisdictions. These changes are designed to mesh U.S. reporting requirements with the rules of the Organization for Economic Cooperation and Development (OCED).

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IRS Proposes New U.S. Tax Reporting by Foreign-Owned U.S. Limited Liability Companies

The IRS has issued proposed regulations requiring a domestic disregarded entity (“DDE”) to significantly increase their reporting and record maintenance, all with the goal of fiscal clarity and enforcement of U.S. tax laws. This will provide the IRS with better access to necessary information and will require DDEs to be more vigilant regarding record-keeping and disclosure.

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A Look at the Impact of New Federal Filing Deadlines

The IRS has recently revised original and extended due dates for tax years starting after December 31, 2015 for several types of returns and reporting forms for both individuals and corporations. In a concerted effort to stagger these due dates, the plan is to minimize the filing and timing issues that U.S. taxpayers had been previously experiencing.

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