This client-centric service model provides dynamic middle market companies with an enhanced understanding of the U.S. and foreign impact of various business decisions, which often impact the profitability of overseas operations as measured by the global effective tax rate. Because tax planning is only one component of international business, we emphasize the need for legal, financial, and operational teamwork so that tax planning evolves within our clients’ overall business objectives.
Our professionals have helped clients at various stages of international expansion:
If you are required to file partnership tax returns, C corporation tax returns, or foreign information reporting (FinCen 114/FBAR), the Surface Transportation Act of 2015 ("the Highway Act") brings some actionable news regarding revised filing deadlines effective for 2016 tax returns. The current partnership return deadline imposes a problem for many partners to timely file their returns by April 15. The partnership due date change may give more time for partners to include any Schedule(s) K-1 income and/or loss on their personal income tax returns and file by April 15.
In a recent speech at the Olympic Training Center in Lake Placid, democratic Senator Charles Schumer of New York, called on the House to pass legislation that would give Olympic and Paralympic athletes a tax exemption on their Olympic medals and monetary bonuses. Schumer expressed that it was wrong to tax these athletes after earning a hard fought victory for the country.
Do you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, or other type of foreign financial account? If you do, and certain thresholds are met, then filing of FinCEN Form 114 Report of Foreign Bank and Financial Accounts will be required to avoid substantial penalties.
The Tax Foundation released a study called the International Tax Competitiveness Index, in which our great nation ranked 32nd out of 34 countries in the Organization for Economic Cooperation and Development in relation to tax competitiveness. The study compared tax systems using over 40 variables in five categories: corporate taxes, consumption taxes, property taxes, individual taxes and international tax rules. The study claims that the US individual income tax system is poorly structured, confusing and has high rates.
The IRS has issued final regulations on the application of the rules that require certain domestic entities to annually report their interest in certain foreign assets effective for tax years beginning after Dec. 31, 2015. Beginning Jan. 1, 2016, the IRS now requires specified domestic entities - partnerships, corporations, or trusts to also attach Form 8938 to their tax return.