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Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a second …

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Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Advising International Business Ventures: Tax Reform’s New GILTI Tax

In GILTI, International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Advising International Business Ventures: Passive Foreign Investment Companies (PFICs)

In International Tax, PFIC by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  This post focuses on, and provides a short introduction to, the Passive Foreign Investment Company (“PFIC”) rules.   U.S. taxpayers investing in foreign corporations may …

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Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

In CFC, International Tax by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometime unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  This post focuses on, and provides a short introduction to, the Controlled Foreign Corporation (“CFC”) rules under Subpart F of the Code.   Historically, U.S. …

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Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

In CFC, International Tax, Participation Exemption, Tax Reform by Jason FreemanLeave a Comment

The Tax Cuts and Jobs Act (“TCJA”) led a shift from a “worldwide” tax system towards a territorial tax system—more accurately, a “quasi”-territorial tax system.  The TCJA accomplished this through several major reforms.  First, it enacted a “toll charge,” or transition tax—a one-time tax on the deemed repatriation of earnings held offshore. In exchange, it implemented a “Participation Exemption System” that …

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International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

In FATCA, International Tax by Jason FreemanLeave a Comment

Earlier this year, the IRS launched and joined the Joint Chiefs of Global Tax Enforcement, known as the “J5,” in an effort to crack down on international tax fraud, money laundering, and cryptocurrency-related crimes. The J5 includes agencies from the United Kingdom, Canada, Australia, and the Netherlands, along with the IRS. The initiative involves a stated effort to share information …

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New Changes Are Coming to Partnership Withholding

In International Tax, Offshore Tax, Partnership Tax, Tax Reform by freemanlawdevLeave a Comment

Section 13501 of the Tax Cuts and Jobs Act created a withholding requirement on the transfer of non-publicly traded partnership interests[1] by amending §§864(c) and 1446 of the Internal Revenue Code.[2]   Section 864(c)(8) provides that gain or loss from the sale, exchange, or other disposition of a partnership interest by a nonresident alien or foreign corporation is effectively connected with …