In the global economy the growth of royalties and services associated to intellectual property and information technology has become critical for international taxation. On one-side governments of importing countries regularly source payments as territorial, based on the jurisdiction or location of payor. On the other, exporting countries push to resolve the issue through tax treaties.…
Read more
Foreign Investors in U.S. Partnerships Miss Schedule P
Foreign investors often miss Schedule P. It applies to the ownership of any U.S. partnership including a limited liability company. Many foreign investors use a foreign corporation with the hope of avoiding US estate taxes. Now, the 2011 Schedule P (Form 1120-F) is required by a foreign corporation’s ownership of a U.S. partnership. Schedule P…
Read more
U.S. Wins Three Tax Cases Involving Big Banks, KPMG
United States prosecutors said Tuesday they had won three major cases against American clients of questionable tax shelters, including ones used by a Dallas billionaire and Wells Fargo Co. and others designed by Citibank and accounting firm KPMG LLP. The separate cases, the verdicts of which were rendered in October, represent a significant victory for…
Read more
Final Form 8939 and Instructions Now Available
The IRS just released the final Form 8939 and Instructions. Form 8939 is required to be filed by an Executor of a 2010 decedent’s estate to make the election to opt out of the federal estate tax system and apply the modified carry-over basis rules under Internal Revenue Code (“IRC”) Section 1022. The deadline for…
Read more
