International
IRS Final Regulations on Foreign Tax Credits: New Compliance Headaches
At a Glance: IRS Final Regulations Update: The IRS has released the long-awaited final regulations for foreign tax adjustments, which the…
International Tax M&A Due Diligence for U.S. Government Contractors
Many US government contracting companies are continuing to expand their global footprint by performing contracts in other countries. The opportunity…
New International Tax Reporting Required with Partnership and S Corporation Tax Returns
In recent years, the IRS has continued to emphasize U.S. international tax reporting as a high enforcement priority. U.S. taxpayers…
S Corporation Acquisitions with Foreign Target Corporations
There are a couple of different structuring options for the acquisition of an S corporation. A buyer that is a corporation…
Earnout-Basics
Diageo built a $300M, 10-year earnout into their $1B acquisition of Casa Amigo Tequila. Earnouts are being used more and…
U.S. Individual Shareholders of Controlled Foreign Corporations May Elect to Decrease Tax on GILTI
The Tax Cuts and Jobs Act (TCJA) enacted various US international tax provisions. The new law includes the US federal…
U.S. Shareholders of Foreign Corporations and the Moving Target of Form 5471
The 2017 Tax Cuts and Jobs Act (TCJA) enacted significant changes to the U.S. international tax regime. U.S. shareholders are…
U.S. Government Contractors and Cross-Border Payroll Tax Issues
The cross-border global expansion of business activities continues to increase exponentially in the US government contracting industry. Many government contracting…
Yelena Epova as a special guest on “Business Radio X” podcast
Listen to the podcast here! Yelena Epova is the partner-in-charge of the international tax services at Aprio. She specializes in advising domestic and…