International Tax Issues for Newly Multinational Corporations A Due-Diligence Perspective
A taxpayer that ventures into international business by acquiring a multinational target may encounter a number of tax issues that could result in significant unanticipated tax liabilities
Published on April 01, 2013
International Tax Compliance for Auditors and CFOs
In an environment where international tax examinations will play a larger role in tax audits, prudent financial executives and auditors will take the time to evaluate their current international tax compliance, assess any shortcomings, and...
Published on January 01, 2010
Comparing International Tax Systems in the Introductory Tax Class
This column describes an assignment that requires a modest time commitment to bring international tax issues into the introductory tax course and to raise student awareness of differences in tax systems
Published on November 01, 2010
International Individual Income Tax Summary Table
From the November 2010 article Comparing International Tax Systems in the Introductory Tax Class this table summarizes characteristics of the individual income tax for a number of countries for which tax system information is currently readily available...
Published on November 02, 2010
Opportunities for Incorporating International Tax Law Into All Levels of the Tax Curriculum
Considering the global nature of today’s businesses, covering international topics is necessary at all levels of the business curriculum
Published on May 01, 2012
Cost-Sharing Agreements and the Arms-Length Standard
The Xilinx case has created turmoil in the international tax community for quite some time, and there is no clear end in sight. Although the Ninth Circuit reversed its controversial decision, uncertainty surrounds the validity of Treasury’s new...
Published on January 01, 2011
Guide to Corporate Blockers
This guide illustrates the U.S. income tax consequences of operating and disposing of a domestic or foreign corporate tax blocker under several common scenarios
Published on October 01, 2011
IRS Releases Procedures Allowing Appeals Review of International Penalties Prior to Payment
The IRS has made it a priority to improve voluntary compliance with the international tax provisions and to reduce the tax gap attributable to international transactions. This focus on international compliance has led to increased enforcement of international information-reporting requirements and the associated...
Published on January 01, 2011
Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part I)
This article explains the procedures and tax compliance issues that fiduciaries face before domestic trust or estate distributions are paid or allocated to foreign beneficiaries
Published on December 01, 2012
IRS Changes Name, Expands Focus of LMSB Division
The IRS announced that it is reorganizing and changing the name of its Large and Mid-Size Business division as part of its ongoing effort to focus more on international tax compliance. Starting October 1, 2010, the division will be known as the Large Business and International (LB&I) division
Published on October 01, 2010