The Bureau of Economic Affairs (BEA) is a division of the US Department of Commerce. The BEA administers the so-called Form BE-10 survey, which is an intensive information gathering tool of the US government. The BE-10 is used to collect information on how US persons are investing abroad and on foreign investment in the US. … Continue reading WAKE UP CALL: Form BE-10
A very important building block when establishing a business is selecting the best type of entity from both a legal and tax perspective. This “choice of entity classification” can make a huge difference in liability protection and tax outcome. When an international business is involved, it should come as no surprise that the complexities only … Continue reading Check-the-Box Election: Is it Really that Simple?
In Rev. Proc. 2020-20, the Internal Revenue Service (IRS) provided relief to foreign citizens who were caught out by travel disruptions occasioned by the corona virus, and as a result, remained in the United States for too many days thereby causing them to be subject to US income tax. Under the Revenue Procedure, the IRS will … Continue reading COVID-19 Relief: IRS Helps Foreigners Having Prolonged Presence in the US
Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE). In addition they may be able to exclude certain amounts paid for foreign housing using the Foreign Housing Exclusion (FHE). Both of these benefits are … Continue reading Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test
As set out in detail in my earlier blog post, the CARES Act amended Internal Revenue Code section 172(b)(1) to provide for a carryback of any net operating loss (NOL) arising in a tax year beginning after December 31, 2017, and before January 1, 2021, to each of the five tax years preceding the tax … Continue reading IRS Provides CARES Act Guidance for Taxpayers with NOLs
On April 9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments
With tax filing time looming, US taxpayers abroad should take heed when claiming the Section 911 “Foreign Earned Income” and “Foreign Housing Exclusion” benefits (FEIE). Two recent cases show how easy it is to lose the FEIE benefits granted to qualifying taxpayers living and working in a foreign country. (My blog post here explains the … Continue reading No FEIE/ Section 911 Exclusion – Stuck in the USA Due to COVID-19? Taxpayers With a US “Abode”
On March 25, 2020, the Senate unanimously passed (96-0) the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) providing desperately needed relief to, among others, individuals and businesses suffering economic distress wrought by the COVID-19 pandemic. Two days later, March 27, 2020, the House of Representatives passed the CARES Act by voice vote and President Trump signed … Continue reading COVID-19 and Losses, Losses, Losses ….NOL Tax Relief from the CARES Act
On February 12, Senate Finance Committee Ranking Member Ron Wyden, D-Ore., and Senator Sherrod Brown, D-Ohio, introduced legislation to prevent the Treasury Department from carving out an exception (commonly called the GILTI High Tax Kick-Out) for multinational companies to escape the so-called GILTI provisions of the Tax Cuts and Jobs Act (TCJA). The title of the … Continue reading GILTI High Tax Kick-Out Election — Kicked Out by Dems!
Please pass this along to your friends and colleagues who may have an interest. The International Business and Structuring Association is hosting an event where I, along with other industry leaders, will be covering the unique challenges and opportunities faced by businesses and investors engaged in cross-border transactions between the US and UAE. I hope … Continue reading Business & Investment Structuring Between the USA and UAE