Tag Archives: international taxation

G Election Trues Up Timing to Recognize CFC & PFIC Income for Net Investment Income Tax

The “G” election,  provided for under U.S. Treas. Reg. Section 1.1411-10(g), impacts U.S. direct and indirect individual shareholders of controlled foreign corporations (“CFCs”) and passive foreign investment companies (“PFICs”). A U.S. individual shareholder of a CFC or PFIC with a qualified electing fund (“QEF”) election is required to report and pay U.S. federal tax on […]

Read more ...

IRS Issues New Transfer Pricing Audit Roadmap

The IRS released a Transfer Pricing Audit Roadmap on February 18, 2014.  The Roadmap, which was issued through the IRS Transfer Pricing Operations of the Large Business and International (LB&I) division, was developed to provide audit techniques and tools for transfer pricing examinations.  The Roadmap is designed as a comprehensive toolkit based on an audit […]

Read more ...

Employment Tax Withholding and Payroll Reporting for U.S. Expatriate Employees Working in Foreign Countries

With increasing globalization and the expansion of cross-border business activities, U.S. employees are often relocating to work in foreign countries.  U.S. expatriate employees typically may work in a foreign country for a U.S. company or for a foreign subsidiary company or foreign affiliate of the U.S. employer.  There are certain U.S. federal tax considerations that […]

Read more ...

FATCA Withholding Begins July 1, 2014

When does the new FATCA withholding begin?  Effective July 1, 2014, withholdable payments of U.S.-source FDAP income will be subject to 30% FATCA (Foreign Account Tax Compliance Act) withholding.  The new requirement applies to payments made to Foreign Financial Institutions (“FFIs”) and Non-Financial Foreign Entities (“NFFEs”).  The types of income that are subject to the […]

Read more ...

The Importance of Sourcing Software License Royalty Income

If a U.S. company pays a royalty to a foreign company for the use of a software license, there is an issue regarding whether the royalty payment is considered to be U.S. source income to the foreign licensor. If the royalty is considered to be U.S. source income to the foreign licensor then I.R.C. Section […]

Read more ...

View Archives

Blog Authors

Latest Webinar Videos