International

Offshore Voluntary Disclosure Program Still Open for Quiet Disclosures and Formal Disclosures

In January 2012, the IRS extended the Offshore Voluntary Disclosure Program. The program allows U.S. taxpayers to pay penalties and…

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Caution: More than One Type of U.S. Federal Tax Withholding Could Be Required for Foreign Partners in a U.S. Partnership

It is very important for a U.S. partnership to determine the residence status of all partners in the partnership. A…

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The Basics to Know About Foreign Tax Credits

1. Foreign Taxes Paid by a US Company Conducting Business Activities Directly in a Foreign Country or through a Foreign…

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International Tax Series: Be Aware of the Form 8858 Filing Requirement if a U.S. Person Owns a Foreign Disregarded Entity

The Form 8858 is required to be filed if a U.S. person owns 100% of a foreign eligible entity that…

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International Tax Series: Are You a U.S. Shareholder in a Controlled Foreign Corporation? The Basics to Know about Subpart F

A controlled foreign corporation (CFC) is a foreign corporation of which more than 50% of the vote or value of…

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International Tax Series: Be Aware of the Form 5471 Filing Requirement if a U.S. Person Owns Stock in a Foreign Corporation

The Form 5471 may need to be filed if a U.S. person owns an interest in a foreign corporation.  A…

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