International Tax

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 Freeman Law 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 Freeman Law 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 Freeman Law 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
Cross-Border Tax Insights, International Tax

Mexico v. Smith and & Wesson: Cross-Border Implications

By Freeman Law Jul 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
Cross-Border Tax Insights, International Tax

Mexico Banking and Finance

By Freeman Law Jun 27, 2022
Cross-Border Tax Insights, FBAR, International Tax, IRS Regulations, Streamlined Filing

Can the IRS Deny My Submission under the Streamlined Filing Compliance Procedures?

By Jason B. Freeman Jun 27, 2022
Corporate, Cross-Border Tax Insights, International Tax

Foreign Investment Regulation: Mexico

By Freeman Law Jun 20, 2022
Cross-Border Tax Insights, International Tax

U.S. Mexico Economic Relations: An Overview

By Freeman Law Jun 13, 2022
Cross-Border Tax Insights, International Tax, Withholding

Exempt Payments to Non-Resident Aliens and Federal Withholding

By Jason B. Freeman May 26, 2022