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International Tax Compliance But it's one that will reap big rewards if you choose to pursue it. We work with everyone from manufacturers and distribution businesses to law firms, technology, retail, and many others. Citizens with tax preparation services to U.S. expats world-wide, primarily in Europe and the Middle East. We will do our utmost to provide our clients with normal service but in these exceptional times that may be challenging and we would ask that you take this into account. Unrelenting commitment to offering the best service to myself and my company as well as sincere considered advice as my business has grown which has been an invaluable asset.    The agency updated its relief information earlier in June 2020. The 2017 Foreign Earned Income Exclusion has increased to $102,100, up from $101,300 for tax year 2016. This means that a husband and wife can make up to $204,200 of earned income using the 2017 Foreign Earned Income Exclusion and pay zero Federal income tax.    Between US tax rules and the EU rules under the Anti-Tax Avoidance Directive II , hybrid debt is more likely to create issues than to solve them. Prior to the 2017 Tax Act, US buyers of foreign target companies routinely made Section 338 elections to obtain a higher value in the target's assets. After the Act, US buyers will continue to have incentives to make the election.    You want to be confident and in control, but the complexity of global tax laws leaves you feeling stressed and overwhelmed. Must have 3 years of experience in tax due diligence, deal structuring, and post-acquisition planning. Our services are of particular value to those who live, work and, or invest across Canadian and U.S. borders, in order to optimize and protect assets and in order to avoid exposure to double taxation.    Warren found something in how I was setup, which turned my situation around to getting $15k returned to me. We fully implement your tax plan to ensure you meet all local and international legal requirements. We provide a written report with options to minimise your tax along with our recommendations. After a thorough analysis of your data and unique circumstances we advise you of all oppotunities.    We are the American Institute of CPAs, the world’s largest member association representing the accounting profession. Our history of serving the public interest stretches back to 1887.    With the help of an experienced CPA you can lower your tax, minimize or eliminate certain interest and penalties, and avoid tax liens and levies by acting now. The IRS dedicates significant resources to collect taxes in the following countries.    Global growth opportunities have changed where and how companies conduct business – presenting both new sources of revenue and new challenges. Reducing tax burden, while minimizing associated risk, is a significant factor in the bottom-line success of global operations. The problem is complexity with global tax laws, which leaves you feeling stressed and overwhelmed. We believe you already have a lot on your plate and you shouldn’t have to become a global tax expert, which is why we help you navigate mobility tax laws in more than 100 countries. We manage every detail of your mobility tax program efficiently and accurately through a mobility tax team dedicated to your business.    The IRS has established several programs that offer eligible taxpayers reduced penalties in exchange for the voluntary disclosure of unreported income and accounts. If you have undisclosed US or foreign income to report, we can help you explore your options for participating in programs like the IRS-CI Voluntary Disclosure Program or Streamlined Filing Compliance Procedures. Our international tax expertise is vast and we’d love to put our knowledge to work for you. Experience the CST difference - integrated U.S. tax advice from dedicated consultants, advisors, and accountants who understand your issues. Are you a U.S. taxpayer, trust or business facing penalties for not reporting overseas accounts?    However, those deductions were never allowed for international charities unless registered in the U.S. Only US domestic charities can receive tax-deductible donations.    If you owe back taxes, the overseas tax amnesty program may provide a streamlined way to settle with the IRS and avoid steep penalties and possible prosecution. The IRS released relief measures (Rev. Proc , Rev. Proc. ) in April 2020. In brief, the measures allowed nonresident individuals, foreign corporations, and partnerships to choose a 60-day period between Feb. 1 and April 1 in which the IRS would not consider their U.S. activity to trigger a tax liability.    Taking advantage of each country’s strengths, the J5’s initial focus was on enablers of tax crime, virtual currency and platforms that enable each country to share information in a more efficient manner. Within the framework of each country’s laws, J5 countries shared information and were able to open new cases, more completely develop existing cases, and find efficiencies to reduce the time it takes to work cases. Operational results have always been the goal of the organization and they have started to materialize. Although I thought the result I had figured out with my accountant were the most tax effective way I could setup myself up.    He is frequently called upon to speak for professional organizations and has authored articles on international tax-related topics. In his free time he enjoys fishing, reading and traveling with his family. Our thoughts and strategies on emerging tax and business issues. Helping clients gain a competitive advantage is what sets us apart. Its our passion to partner with our clients and provide the custom business solutions to support their success.    The CFC's holding company would then sell the target's stock to the buyer. This sale would then be treated as an asset sale for US tax purposes, and with limited exceptions, would not generate Subpart F income. Consequently, the sale would not have any immediate US tax consequences. ACAT seeks to ensure that all accredited individuals possess the theoretical and practical knowledge necessary to be successful practitioners. For that reason, candidates for accreditation must satisfy a three-year experience requirement before becoming fully credentialed.    Another way to give internationally and receive a tax deduction is through a donor-advised fund. Donors can set up charitable gift accounts through a national charitable fund such asSchwab Charitable, and theCalvert Foundation. If you do think you can take a charitable tax deduction, by all means, do so. Just check with the organizations you are considering to make sure that your contribution is tax-deductible. Look for the 501 designationin the materials the charity provides or on its website.    A capital loss generated in this manner might be more beneficial in situations where the target CFC is directly owned by a US parent company. The capital loss would then arise in the US tax return and this could be used to offset US capital gains. Following US tax reform, it will not be easy for CFCs to accumulate material amounts of non-taxed E&P. From 2019, most CFCs and their E&P will be taxed as either Subpart F income or GILTI.    Citizens and residents living and working outside the U.S. may be entitled to a foreign earned income exclusion that reduces taxable income. In addition, you may exclude housing expenses, but with limits. There are limits and special rules about who qualifies for the exclusion, andwe can help you understandif you qualify.    Governments and other authorities worldwide are introducing measures to help businesses prepare and respond to the fiscal and financial impacts of COVID-19. Unique circumstances arise when sending workers abroad—causing major tax headaches for your organization. For 20 years, GTN’s global tax experts have been dedicated to you and your program. Stay one step ahead of questions and remain compliant with tax authorities. Must have 1 year of experience supervising the planning and execution of projects, including managing budgets.    We guide you towards the best path and take control of implementation. Through every stage, we ensure full tax compliance and ongoing support.    Australian tax residents are typically taxed on their worldwide income. If you have assets abroad, you need to understand what and how to declare your foreign income. D&H Global Tax Group understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described in our Privacy Statement, and in a way that is consistent with our obligations and your rights under the law. This privacy statement refers to provided by UKUS Tax Services LLP an affiliate of D&H Global Tax Group.    Completed multi-step FIRPTA withholding exemption process via IRS Form 8288-B and Form 593-C . Created closing financial statement and dissolved the offshore holding company with assistance of foreign administrators.    Contributions are tax-deductible immediately and can be "bunched" so that one can make the equivalent of several years of donations and then distribute that money over time to charities. Contributions to a donor-advised fund can be in the form of cash or securities.    In general, a stock sale would produce Subpart F income for the CFC holding company, which is subject to an immediate 21% US corporate tax rate. According to this model, the target CFC would 'check a box' in order to be treated as a disregarded entity for US tax purposes.    The ideal candidate has 5+ years of in-depth HNWI Tax experience, a CPA or Enrolled Agent license, as well as excellent communication skills in verbal and written format. We offer accounting and advisory services for non resident aliens to ensure they are fully proficient with their finances. From the preparation of accounts to advising US citizens living in the UK and abroad on all aspects of taxation. We’ll share the cost of your expat tax preparation before we start on your return.    Up until recently, charitable tax deductions have been a powerful incentive for Americans to donate to charities. Now, with new tax laws, it takes a much larger donation to qualify for a deduction.    However, the earnings of such a CFC would generally not be taxable by a US subsidiary treated as its owner by attribution. In cases where the target CFC remains a CFC in the hands of the buyer, the allocation of the target CFC's GILTI-tested income in the year-of-sale raises novel questions. This situation could also arise in the case of a sale to a US buyer or in the sale to a foreign buyer with one or more US subsidiaries.    If you are making an enquiry for the FIRST TIME with Wealth Safe and interested in becoming a new client, book in your “no obligation” high-end advice strategy session by completing your details below. Not only does this defeat the purpose, but you also risk running foul of the law. Before long you’re paying more than half of your income towards tax. The material on this site is for financial institutions, professional investors and their professional advisers. non resident alien gift tax Please read our Terms and Conditions and Privacy Policy before using the site.    However, if our initial call lasts for less than 2 hours, you can use the remaining time for questions you may have in the future or apply the balance towards tax preparation services. I’ll send you an E-Invoice to pay the retainer from a US account via bank debit after I receive your introductory email and brief fact pattern. If you would like to schedule a call, please send me an email suggesting a time and make the $975.00 payment or call .    If you are looking for a blend of personal service and expertise, you have come to the right place! We offer a broad range of services for business owners, executives and independent professionals. Canadian Corporations are normally in a good position to save thousands of dollars in social security taxes if the entire tax situation is handled correctly. Prior to coming on as a Global Client Manager in 2019, Chris Mc Laughlin worked in law enforcement and security, and has previous experiences in sales and client management. He now manages new client accounts across Asia and coordinates with our partners around the world.    In his transactional tax practice, Will has experience advising on a wide range of sophisticated corporate transactions, such as M&A, tax-free reorganisations, financings and restructurings. However, PTEP gives rise to currency gains or losses during repatriation under Code § 986. This may also create basis issues as it is distributed through a chain of foreign ownership.    Canadian residents with US filing requirements often run afoul of the IRS when preparing a US tax return thanks to Canadian registered retirement plans. If you have a Registered Retirement Savings Plan or a Registered Retirement Income Fund , I need to speak with you about navigating the intricate reporting requirements to satisfy the demands of Canada as well as US tax authorities.    This website uses cookies to provide you with the best browsing experience. Provided CFO and foreign tax advisors analysis of impact of permanent establishment and sourcing rules from establishing a co-located U.S. data center.    After 2017, it should be less important to use foreign cash to fund foreign acquisitions than it was before. In theory, the 2017 Act allows for tax-free repatriation of foreign cash, either under the new § 245A dividends received deduction, or as previously taxed earnings and profits . Financing issues will also take on a different character and tone. The 2017 Act imposed numerous disincentives regarding interest deductions on hybrid debt.    We're proud to celebrate over 30 years working with international expat communities around the world. Through all the changes we've seen as our world evolves, our core value to serve our clients wherever they are, remains the same. living abroad, an American investing offshore, or an international investor planning to invest in the United States, our specialist teams of cross-border advisors can help. We are some of the very few practitioners in the expat tax world who are ourselves US citizens and taxpayers.    Today, you'll find our 431,000+ members in 130 countries and territories, representing many areas of practice, including business and industry, public practice, government, education and consulting. When we see legislative developments affecting the accounting profession, we speak up with a collective voice and advocate on your behalf. Our advocacy partners are state CPA societies and other professional organizations, as we inform and educate federal, state and local policymakers regarding key issues.    The United States vigorously pursues taxes worldwide and a common mistake many Expats make is assuming their US tax obligations disappear once they move overseas. In fact the US maintains tax treaties with over 66 countries which exchange tax information with the IRS. The US spends over 5 billion dollars a year in the auditing, discovery, collections and prosecution of US citizens living or working abroad. All of this work yields more than 55 billion dollars in additional tax revenue for the IRS.    He started in 1995 in his fathers CPA firm and progressed to being the international expatriate tax specialists for a surviving remnant of Arthur Anderson. He has a Bachelors in Global Business Management from the University of Phoenix and a Juris Science Masters in International Tax and Financial Service Law, from Thomas Jefferson School of Law. Leon’s substantial skills allow him to conduct seminars and teach international tax through various public mediums.    If you decide to proceed with a professional relationship, I would prefer to review documents prior to the consultation. Sensitive documents may be sent securely using my Secure Portal.    Advised client on recent changes to IRS Form 2848 ; created alternative method for continuing critical business process for filing 1040NR and receiving refunds on behalf of its foreign investors. Avoidance of immediate taxation under Subpart-F rules through active-leasing exception. In May 2010 the IRS released a document which has continued to be beneficial for clients who are considering a SIPP as the solution to the management of their existing international pension. Few financial considerations are as important to the British expat in the United States as the management of their existing international pensions. First and foremost, expats should remember that a UK pension cannot be transferred to a US scheme; neither a 401k nor an IRA retirement plan will accept payments from a UK pension scheme.    However, the US ranks near the bottom of all countries when it comes to international aid dollars. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms.    Cutting edge technical tax and business strategies we’ve authored in publications around the world. Advisory & Accounting Whether you are a start-up or an established business analyzing a large acquisition, let us share our experience with you. Donor-advised funds work well for donors with at least $5,000 to invest.    The higher value will increase depreciation and amortisation deductions, resulting in reduced amounts of GILTI-tested income. Overall, the 2017 Act's repeal of § 958 allows for a 'downward attribution' of stock ownership from a foreign parent company to its US subsidiaries. As a result, a CFC could technically remain a CFC after a sale to a foreign multinational buyer.    Charitable tax deductions can only be claimed for donations given to this type of nonprofit. Five percent of charitable giving for international causes seems shockingly low when compared to other countries. Many Americans think that our government spends a lot on foreign aid, so why should we worry?

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