International Tax

March 2017

Form 926 Filing Requirements – a Potential Trap for the Unwary Tax-Exempt Organization

By | March 31, 2017|Categories: Nonprofit, Taxing Thoughts|Tags: , , , |

By: Sunil Patel (Tax Supervising Senior) and Jason Booth (Tax Principal) Many tax-exempt organizations invest frequently in foreign alternative investments (e.g., hedge, private equity, real estate and venture capital funds). When investing into such funds, these tax-exempt organizations’ primary tax concern is generally to mitigate their risk of Unrelated Business Taxable Income (“UBTI”). Funds commonly [...]

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August 2016

Travel Has Made Me a Better Accountant

By | August 17, 2016|Categories: #BeMore|Tags: , , , , , |

By Polina S. Chapiro (International Tax Partner, Green Hasson Janks) As an international tax expert, traveling to countries around the world gives me a perspective and sense of how other people live and do business. I’ve been to many countries in Europe (to some several times), as well as to Africa and China (including Hong [...]

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March 2016

The IRS’s International Focus

By | March 25, 2016|Categories: Taxing Thoughts|Tags: , , , , , , , , , , , , , , |

By Jason Booth (Principal, Green Hasson Janks) For years now an ongoing debate has taken place on Capitol Hill about U.S. international tax policy reform.[1] Amongst many others, arguments have been made regarding lowering the U.S. corporate statutory tax rate (in 2015, it was the higher than any other Organisation for Economic Co-operation and Development [...]

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February 2016

Australia’s New “Netflix Tax”

By | February 19, 2016|Categories: Media Clips, Taxing Thoughts|Tags: , , , , , , , , |

By Jason Booth (Principal, Green Hasson Janks) Just days ago (Feb. 10, 2016), the Australian treasurer introduced draft legislation to ensure that the country’s goods and services tax (“GST”) would apply to digital products and other services provided to Australian consumers by foreign vendors in a way that is similar to how GST applies to [...]

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September 2014

New Rules to Curb Corporate Inversions

By | September 26, 2014|Categories: Taxing Thoughts|Tags: , , , , , , , |

By: Farshad Yashar (Partner, Green Hasson Janks) Over the past two years, a number of high profiled transactions involved U.S. domiciled multi-national companies acquiring a foreign-based company resulting in the U.S.-based acquirer changing its domicile to the country of the foreign company that it had acquired.  This is broadly referred to as an "inversion" transaction, which is [...]

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February 2014

House Ways and Means Committee Releases Tax Reform Proposal

By | February 27, 2014|Categories: Taxing Thoughts|Tags: , , , , , , , |

By: Farshad Yashar On Tuesday, February 26, 2014, House Ways and Means Committee chairman Dave Camp released his long-awaited draft legislation on tax reform. The draft is a 979 page report titled "Tax Reform Act of 2014." If enacted, the draft legislation would usher the single biggest overhaul of the tax code since 1986. The [...]

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April 2013

Proposed Tax Changes from the “Green Book”

By | April 23, 2013|Categories: Taxing Thoughts|Tags: , , , , , , , |

The United States Treasury recently released the so-called "Green Book," which is the Administration's Fiscal Year 2014 Revenue Proposals. The Green Book is the President's wish-list of tax changes, and as usual, this year's wish-list is a cornucopia of tax proposals - past and present. The proposals include tax changes for businesses and individuals. This [...]

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May 2012

Benefits and Burdens of U.S. Citizenship

By | May 15, 2012|Categories: Taxing Thoughts|Tags: , , , , , , , |

The name of Eduardo Saverin recently appeared on the Federal Register list of U.S. citizens who have renounced their U.S. citizenship. Saverin who was born in Brazil and currently resides in Singapore is best known as a Facebook co-founder and a soon-to-be billionaire. The motivation for renouncing his citizenship was thought to be tax related [...]

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March 2012

The Big Apple

By | March 21, 2012|Categories: Taxing Thoughts|Tags: , , , , , , , , |

On Monday, Apple announced that it is planning to pay a significant dividend to its shareholders for the first time since 1995. The dividend plan is being maneuvered through a maze of U.S. tax issues having to do with repatriating off-shore income. According to its latest regulatory filing, Apple is sitting on a cash hoard [...]

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February 2012

The IRS “Dirty Dozen”

By | February 22, 2012|Categories: Taxing Thoughts|Tags: , , , , , , , , , , , , |

On February 16th, the IRS published its list of top 12 “tax scams” for 2012 dubbed the “Dirty Dozen.” “Taxpayers should be careful and avoid falling into a trap with the Dirty Dozen,” said IRS Commissioner Doug Shulman. “Scam artists will tempt people in-person, on-line and by e-mail with misleading promises about lost refunds and [...]

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