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If you purchase real property from a foreign person or entity, you may be required to withhold taxes from your payment to the seller under the Foreign Investment in Real Property Tax Act (FIRPTA). The federal tax law is designed to ensure that foreign sellers pay any applicable capital gains tax on profits realized from […]

Denial of Treaty Benefits and Limitation of Benefits One of the hallmarks of international tax planning is the ability to obtain a tax ruling from a foreign revenue services that the taxpayer is a qualified resident for income tax treaty purposes. Such a ruling permits a taxpayer to proceed with certainty in establishing operations. It […]

Increase of offshore account penalties The IRS recently warned that the agency has collected $8 billion in taxes and fines collected from offshore bank account penalties which were a result of not conforming to the Foreign Account Tax Compliance Act. According to a report by Forbes contributor and tax lawyer Robert Wood, the IRS has begun to […]

According to a Forbes report last week, Walmart has $76 billion in foreign tax havens. The report claimed that the world’s largest retail chain has 78 subsidiaries in 15 overseas tax havens where the company has no store locations. Walmart’s hidden assets The report claimed that Walmart is effectively avoiding U.S. corporate taxes on overseas […]

For international companies, it may be time to start registering your intellectual property in Cuba. While the country is not yet officially open for business to American businesses, you can protect your trademark rights now. As we previously discussed on the Scarinci Hollenbeck Business Law News Blog, President Barak Obama recently unveiled a plan to […]

Microsoft is being audited by the IRS and they demand leaders testify The IRS is suing a number of former and current executives of Microsoft in a bid to force them to testify in an investigation into the company’s corporate tax practices. According to The Seattle Times, at issue is whether the company is following […]

How is international law going to be affected once China begins to enforce this new law? China represents significant opportunities for U.S. corporations, with exports alone totaling $161 billion in 2013. However, the country’s legal unpredictability increases the risks of conducting business in terms of international law. To improve trade relations, officials from China and […]

What Does the Executive Order Regarding Immigration Mean for Your Business? Amidst the political debate surrounding President Barack Obama’s executive order regarding immigration, many have overlooked how the new policies will impact U.S. businesses. In fact, there are several measures intended to help U.S. businesses hire and retain highly skilled workers and attract foreign entrepreneurs. Below […]

The Last Known Address rule embodies one of the great unrecognized perils of taxation. The rule provides that the IRS must send notices, such as a Notice of Deficiency for assessed taxes, to the last known address. A taxpayer has 90 days from the date of the Notice of Deficiency to contest the deficiency in […]

As was widely reported a few months ago, Burger King is expected to complete a corporate inversion by purchasing Canadian donut company Tim Horton. Spinning both companies into subsidiaries of a new, multinational fast-food company headquartered in Canada. New numbers released by tax watchdog Americans for Tax Fairness showed just how much Burger King will be […]

The ‘Oracle of Omaha,’ billionaire investor Warren Buffet, is still touting the importance of higher taxes. Buffet said Oct. 6 that the recent White House action to limit tax inversions – in which companies shift their headquarters outside the U.S. to lower their tax bills – provides a good “time out” for the government to work on a […]

The U.S. Treasury Department announced Sept. 22 that it will move to disincentivize the practice of corporate inversions. A corporate inversion occurs when a multi-national business merges with a company overseas to take advantage of the lower tax environment to be had there. Treasury Secretary Jacob Lew explained to reporters on a conference call that a […]