Accessing Cash from CFC or non-CFC Foreign Subsidiary. If you have liquidity needs and own one or more foreign subsidiaries, it may be possible to access cash held by the CFC in a tax-efficient manner.
Recently, the rating agency Fitch said the coronavirus pandemic has significantly weakened India’s growth outlook for this year and exposed the challenges associated with a high public-debt burden. Matching Moody’s view, it has downgraded
India has recently cut its corporate tax rates in a bid to revive its stagnant economy. The move has widely been seen as a positive and much needed one and sees the rates cut as follows: Companies that don’t seek exemptions will see their tax rate cut from 30% to 22% before surcharge and cess.
While organisations often overlook tax-compliance requirements related to business travel, the days of simply traveling to and working in a different state or country for business without a thought to tax liabilities are coming to an end. Looking for additional tax revenue, US state taxing authorities are becoming stricter and more vigilant in monitoring business travel. Extensive time spent on business travel in a country outside the US, or even a different state within the US, could create a PE exposure for the employing entity.
As long as greed exists, so does corruption. To combat corruption, the US enacted the Foreign Corrupt Practices Act (FCPA). Its provisions prohibit offering, authorizing, or making payments of money or anything of value to influence the decision making of foreign government officials to obtain or retain business.
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.
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.
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.
Andrea Fantozzi , a Partner and Director at the Italian Desk in the International Department of Prager Metis CPAs, is presenting at the Export U. S. A seminar May 31st, 2018.