International Services

While Relinquishing One’s US Citizenship Can Mitigate Estate and Gift Tax Obligations

Relinquishing one's US citizenship can mitigate an individual's estate and gift tax obligations, but a "Covered Expatriate"* should plan carefully when disposing of assets. Internal Revenue Code Section 2801 imposes a tax on US citizens or residents who receive certain gifts or bequests from Covered Expatriates (CEs). Even if the property is non-US-situs property, all of it is subject to the 2801 taxing regime.

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While Relinquishing One’s US Citizenship Can Mitigate Estate and Gift Tax Obligations2019-10-15T15:01:17-05:00

US Anti-Corruption Laws and Their InternationaI Reach

As long as greed exists, so corruption. To combat corruption, the US enacted the Foreign Corrupt Practices Act (FCPA). Its provisions prohibit offering, authorising, or making payments of money or anything of value to influence the decision making of foreign government officials to obtain or retain business.

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US Anti-Corruption Laws and Their InternationaI Reach2019-10-28T12:00:14-05:00

How the Change in US Sales Tax Rules has Impacted International Sellers

On 21 June 2018, the US Supreme Court passed a landmark decision that transformed the landscape of sales tax in the US. The South Dakota vs Wayfair decision effectively permitted states to create new rules for sales ­tax collection requirements based on the dollar or transactions amount of sales - otherwise known as economic nexus. Previously, companies were only required to collect sales tax based on a physical presence test.

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How the Change in US Sales Tax Rules has Impacted International Sellers2019-10-15T14:41:12-05:00

Tax Planning Under the New US Tax Reform

The US Tax Cuts and Jobs Act, passed on 17 December 2017, has dramatically changed the analysis and available strategies for structuring cross-border operations. Meaning, to realise tax optimisation, business owners must be aware of those changes. For example, in addition to a decreased corporate rate from 35% to 21%, and the full expensing of plant and equipment acquisitions, there is a now a reduced effective rate of 13.125% for domestic companies’ income from selling products or services to foreign customers directly or through related parties.

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Tax Planning Under the New US Tax Reform2019-10-31T10:34:20-05:00

Il Fisco Americano terminera’ il programma di Voluntary Disclosure

Partner Andrea Fantozzi, a Director at the Italian Group in the International Department of Prager Metis CPAs, was published in America 24. Click here to read the full article titled: Il Fisco Americano terminera’ il programma di Voluntary Disclosure.

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Il Fisco Americano terminera’ il programma di Voluntary Disclosure2019-03-29T17:04:47-05:00

IRS, Treasury Department Finalize Reporting Regulations for Foreign-Owned U.S. Disregarded Entities

For years, limited liability companies (LLCs) in America with a single foreign owner were not subject to U. S. tax reporting requirements. However, final regulations recently issued by the Internal Revenue Service (IRS) and the Treasury Department have effectively closed that loophole, significantly raising the tax filing complexity and record-keeping burden on these entities.

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IRS, Treasury Department Finalize Reporting Regulations for Foreign-Owned U.S. Disregarded Entities2019-03-29T17:28:07-05:00