In this episode, Director of Tax Services Pedro Porras, CPA, explains the changes in the OBBB that will impact international citizens, companies and taxpayers.
The One Big Beautiful Bill Act (OBBBA) modifies several international tax laws introduced in 2017 by the Tax Cuts and Jobs Act (TCJA), including a decrease in deductions and changes to the names of the Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII) regimes. The following provisions are scheduled to take effect for […]
In this episode Associate Director of Tax Services Joel Young, JD, LLM, shares an overview of FIRPTA, the goals of the program and who might make a misstep.
The Foreign Investment in Real Property Tax Act (FIRPTA) is a U.S. law enacted in 1980 to ensure foreign owners of U.S. real property interests pay their fair share of federal taxes on the profits they may yield from the eventual sale or disposition of those properties. It requires advanced planning and specific actions by […]
U.S. persons, businesses, trusts and estates with 10 percent or more ownership interest or voting control over a foreign business enterprise in fiscal year 2024 have a quinquennial requirement to file a Bureau of Economic Analysis (BEA) Forms BE-10 by May 30 or June 30, 2025, depending on the number of forms they must file. […]
With the complexity of the U.S. tax code, foreign persons may inadvertently trigger a withholding tax on the sale or disposition of U.S. real estate even when they are party to an otherwise tax-free reorganization. It is important for foreign individuals to understand the nuances of the Foreign Investment in Real Property Act (FIRPTA) and […]
A recent decision by the U.S. Court of Federal Claims may open the door to a potential deluge of requests for tax refunds from U.S. citizens and resident aliens living or working in foreign countries with which the U.S. has an income tax treaty. In Christensen v. United States, the court interpreted the U.S.-France Income […]
In this episode Director of Tax Services Magda Szabo explains when and how to start the process of pre-immigration tax planning.
In this episode international tax advisor Lewis Kevelson shares tips and traps for international families with US assets.
In this episode Director of International Tax Services Lewis Kevelson discusses pre-immigration tax planning and why it’s so important to start before you start the citizenship process.