Tag Archives: international tax

Section 338(g) Election for the Acquisition of a Foreign Target Corporation

A Section 338 election has the effect of recharacterizing a taxable stock acquisition as a deemed asset acquisition. The advantage to the buyer is the step up in the basis of the assets deemed acquired to the fair market value on the date of purchase. In the context of a cross-border acquisition, there are some […]

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Tax Season Reminder: Timely File U.S. Foreign Reporting Forms to Avoid Penalties


The 2014 tax return preparation season brings the opportunity to make sure that U.S. taxpayers are in compliance with their U.S. foreign reporting obligations. U.S. individuals, corporations, partnerships, trusts and estates are required to file certain U.S. forms to report interests in offshore assets and foreign accounts. Most of the forms are due by the […]

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International Payroll for Compensation of U.S. Expatriates and Impatriates

A U.S. company may face international payroll challenges when it sends U.S. employees to work in a foreign country or if it engages foreign individuals to work in the United States. Some U.S. payroll service providers do not have the capability to address the specific U.S. employment tax and payroll reporting issues that often arise […]

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