Latest Publications

Share:

IC-DISC Benefits Enhanced with Foreign Shareholders

Since the reduction in the individual tax rate on qualified dividends in 2004, the Interest Charge Domestic Sales Corporation (“IC-DISC”) has become an attractive vehicle to obtain a tax incentive for exporting U.S.-produced...more

8/18/2014 - Dividends Exports IC-DISC Income Taxes Shareholder Litigation Shareholders Tax Incentives

Inbound U.S. Tax Planning With Inversions

With all of the recent negative publicity focused on the outbound restructuring of U.S. multinationals engaging in so-called “inversion” transactions (see prior blog “Corporate Inversions Showing No Signs of Slowing Down”),...more

8/4/2014 - International Tax Issues Inversion Parent Corporation Tax Planning

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

7/7/2014 - Check the Box Rules Cross-Border Foreign Entities IRS Tax Planning

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

6/13/2014 - Controlled Foreign Corporations Corporate Conversions Dividends Foreign Corporations Foreign Investment Jurisdiction Repatriation Shareholders Subpart F Tax Planning Tax Treaty

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

1/29/2014 - Dividends Foreign Nationals Income Taxes Swap Dealers Swaps Tax Evasion

Editorial: How US Cos. Can Reduce Latin American Tax Obligations

Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries. Originally Published in Law360 - October 29,...more

10/30/2013 - Corporate Taxes Foreign Subsidiaries Tax Deferral Tax Liability

Tax Planning For U.S. Companies With Latin American Operations

Pass-through structures - Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more

10/23/2013 - Corporate Taxes Foreign Subsidiaries Income Taxes Tax Planning

7 Results
|
View per page
Page: of 1