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James J. Miesowicz, CPA

IRS Continues to Refresh and Pursue International Tax Campaigns

April 28, 2021

The IRS’s Large Business & International Division Continues to Refresh and Pursue Issues on its ..

Worldwide Interest Allocation for Foreign Tax Purposes Nixed as Part of American Rescue Plan Act of 2021.

March 8, 2021

If a tree falls in the forest and no one is around to hear it, does it actually make a sound?..

Brutal Results for Foreign Corporation That Failed to File US Tax Returns

March 2, 2021

US Tax Court disallows all deductions for UK company operating in the US on the Outer Continental..

How Are COVID-19 and a PFIC Similar?  Nobody Wants Either One!

February 2, 2021

If you have invested in any foreign corporations, you may be aware that you want to avoid having..

TAX EXTENDERS: LOOK-THROUGH RULE FOR CFCs EXTENDED!

December 28, 2020

Although the provision that allows for the deduction for expenses paid with PPP loan proceeds and..

MOVE OVER FBAR REPORTING: FinCEN WANTS US COMPANIES TO REPORT ON THE BENEFICIAL OWNERSHIP OF US COMPANIES!

December 11, 2020

US companies may already be familiar with the requirements to report ownership of foreign bank..

TITLE TRANSFER ON FOREIGN SALES: TIME TO CHANGE BACK TO THE US?

December 8, 2020

It used to be common for US taxpayers to transfer title to product sales destined for a foreign..

FINAL DOWNWARD ATTRIBUTION OWNERSHIP REGULATIONS DID NOT ELIMINATE “THE MISTAKE”

October 20, 2020

Most international tax professionals and the IRS believe Congress made a mistake (“The Mistake”)..

YEAR-END TAX PLANNING FOR NONRESIDENT ALIENS AND FOREIGN CORPORATIONS “STUCK” IN THE US DUE TO COVID

October 6, 2020

The IRS provided relief to nonresident aliens and foreign corporations affected by the novel..

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