International Tax

Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Form 5471, International Tax, IRS Disclosure, Offshore Tax, Outbound Transfer, Tax Planning

Reviewing a Foreign Legal Structure

By Andrew Mirisis Jan 24, 2023
Cross-Border Tax Insights, International Tax

Maquiladora Program

By Stephanie Uribe Jan 11, 2023
Cross-Border Tax Insights, International Tax

Tax Residency Status Modification: Mexican Tax Implication

By Stephanie Uribe Dec 15, 2022
Cross-Border Tax Insights, International Tax, Trademarks

U.S. and Mexico | Trademark Royalties and Tax Considerations

By Stephanie Uribe Dec 01, 2022
Cross-Border Tax Insights, International Tax, Withholding

NRA Withholdings—No Guns, Just Taxes

By Freeman Law Nov 21, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Participation Exemption, Repatriation, Subpart F, Tax Planning

Strategies to Recharacterize Gain with Untaxed Foreign Earnings

By Andrew Mirisis Nov 02, 2022
Cross-Border Tax Insights, International Tax

The Methods (and Madness) of Transfer Pricing for Tangible and Intangible Property

By TL Fahring Oct 28, 2022
Cross-Border Tax Insights, Form 926, Gain Recognition Agreement, GRA, International Tax, IRS Disclosure, IRS Regulations, Outbound Stock Transfer, Outbound Transfer, Section 367, Section 6038B, Tax Compliance, Tax Planning

Gain Recognition Agreements and Outbound Stock Transfers

By Andrew Mirisis Oct 19, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Deductions, GILTI, International Tax, Participation Exemption, Structuring, Subpart F, Tax Planning

Section 245A Overview and Requirements

By Andrew Mirisis Oct 06, 2022
Cross-Border Tax Insights, International Tax, Withholding

International Tax Withholding | Chapter 3 of the Internal Revenue Code

By TL Fahring Oct 03, 2022
Cross-Border Tax Insights, International Tax

Section 965 Tax Installment Payments Are Not Guaranteed

By Freeman Law Sep 20, 2022
International Tax

International Tax Concepts: Tax Residency Status

By Jason B. Freeman Sep 15, 2022
International Tax

Revoking a Mark-to-Market Election with Respect to a Foreign Company

By Jason B. Freeman Sep 11, 2022
CbC Reporting, International Tax

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

By Jason B. Freeman Sep 07, 2022
CbC Reporting, International Tax

Country-by-Country Reporting

By Jason B. Freeman Sep 06, 2022
International Tax

International Tax Concepts: Dual-Status Taxpayers

By Jason B. Freeman Sep 05, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

By TL Fahring Jul 05, 2022
International Tax, Withholding

Exempt Payments to Non-Resident Aliens and Federal Withholding

By Jason B. Freeman May 26, 2022