A permanent establishment (PE) is an international tax treaty concept important for any business undertaking activities in foreign countries to understand. Ultimately, whenever a company has a PE in a different country, it effectively creates a taxable presence in...
Content provided by Derek Morgan, Senior International Tax Services Manager For immigrants coming to the U.S.—whether they are here for temporary employment, permanent residency, or other similar situations—understanding the intricacies of the U.S. tax and social security systems is...
Navigating the complexities of transfer pricing is a critical aspect of managing a multinational business. This practice involves determining the prices at which goods, services, and intellectual property are exchanged between affiliated entities within the same company. In this...
As the global economy continues to expand, navigating international tax regulations is paramount for both businesses and individuals alike. One such regulation that has significant implications for financial institutions, multinational corporations, and even individual taxpayers is the Foreign Account...
Although many American taxpayers may worry about being subject to an IRS audit, they’re often unsure about why an account gets flagged. Below, we’ll take a look at what an audit entails as well as common reasons why Americans...
Before your bags are packed, take some time to understand the intricacies of expat taxes, including key concepts, deadlines, exclusions, credits, reporting requirements, tax treaties, tax equalization, and some of the most common mistakes.
Leverage Your Playing Field A business’ playing field can be as small as a town or as large as the globe. The playing field is the area in which a business serves clients, faces competition, and in which it...
Changes to the FDII export incentive are driving international companies to shift toward using the U.S. as a base for global sales, services, and licensing.
Over the last several years, unprecedented supply chain disruptions caused by both the pandemic and geopolitical stress have affected the global availability of raw materials, finished goods, labor, and talent. These issues have increased prices for businesses and consumers...
Content Provided by Damian Stanislaw Ponicki, Senior International Tax Associate In an increasingly globalized world, international business transactions have become the norm rather than the exception. For businesses in the United States engaged in cross-border commerce, understanding the nuances...
Content Provided by Damian Stanislaw Ponicki, Senior International Tax Associate The globalized nature of modern finance has led to the U.S. government’s increased push for transparency and oversight when it comes to foreign financial interests held by U.S. taxpayers....
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) finalized a rule last month to extend the deadline for companies created or registered in 2024 to file their initial beneficial ownership information reports. The rule will require most U.S. corporations,...
In September of 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a new beneficial owner reporting requirement for certain U.S. entities in an effort to clamp down on illicit finance and money laundering, pursuant to Congress’ Corporate...
Written by: Fernando Lopez, Partner, International Tax Intellectual Property As a Driver of Revenue Let’s consider a set of U.S. based businesses that are currently going through their initial formative period. Each business offers a promising product or service...
Authored by: Fernando Lopez, International Tax Partner Over the last several years, unprecedented supply chain disruptions caused by both the pandemic and geopolitical stress affected the global availability of raw materials, finished goods, labor, and talent. These issues severely...
Since 1992, the United States and Russia have enjoyed a mutual Income Tax Treaty designed to prevent double taxation and fiscal evasion regarding taxes on income, commonly called the U.S. Russia Tax Treaty. However, two weeks ago (August 16,...
U.S. residential and commercial real estate has been a popular source of investment for foreign persons for decades and easily exceeds $100 billion dollars on an annual basis. Because of the unique way that the U.S. taxes nonresident individuals...
When foreign business owners and investors plan to move to the United States, one crucial aspect of their financial strategy should be pre-immigration tax planning. This planning can significantly impact their tax liabilities and overall financial health once they...
Nonresidents can use a U.S. trust to hold foreign business and investment assets for foreign beneficiaries, which offers tax, estate, and security benefits.
