Tax News

When dealing with international taxation there are many complex laws that can cause unexpected tax; however, the most severe and surprising situations often come from informational reports.  Receiving foreign gifts or inheritances is a perfect example of this situation. There is no tax, fee, penalty, or cost when an American receives a gift or inheritance […]

We are honored to have Partner Josh Maxwell as a panelist for two separate sessions at the virtual Estate Planning and Wealth Succession Asia Forum 2020. Click here more information, Asia Forum

In 2017, certain taxpayers were subject to a one-time tax on earnings in controlled foreign corporations under Section 965, also known as the transition tax.  Since this was a newly created, one-time tax, it was overlooked or unknown by many taxpayers.  However, for a few reasons, it seems that all applicable taxpayers will soon have […]

As we have detailed many times, the transition tax and GILTI were two tax laws that were not designed for individual taxpayers.  Therefore, much of the guidance and regulations have little impact or relevance to individual taxpayers or taxpayers with simple foreign structures.  The new high tax exception is no different as most of the […]

Despite claims of attempting to simplify compliance, in recent years, forms and compliance for international reporting has become much more detailed and complicated.  In keeping with this theme, the IRS has released drafts of new forms to allow partnerships to report international items to partners with greater detail. At first glance, for many taxpayers it […]

Below is the link to our most recent webinar on GILTI and the Transition Tax.  Thank you to AMCHAM Thailand for hosting! Click here for recorded event.

Following up on our blog “GILTI and the Transition Tax:  How, Why and Moving Forward,” HMLLP Partner Josh Maxwell will be presenting on these topics in collaboration with AMCHAM Thailand. For more information or to attend, click here.

In this extended blog we explain the policy problems with these new tax laws, how to address them, and offer some suggestions for the future. GILTI and the Transition Tax: Why, How and Moving Forward

Once it enters into force, the USMCA will replace NAFTA.  Since many U.S. tax treaties make reference to NAFTA, it was unknown if this would cause any issues with these provisions, and despite a recent IRS clarification, it is probably still a bit unknown. References to NAFTA appear in treaties even outside the U.S., Mexico, […]

Between the Tax Cuts and Jobs Act and the coronavirus, there have been many unique tax situations lately.  It was only a matter of time before these started to interact and cause problems.  As part of the coronavirus provisions under the CARES Act, the IRS allowed for certain NOLs to be carried back.  This carryback […]