Several recent international business developments generate cautious optimism for some San Diego business owners. While we await the work the US Congress intends to do on corporate taxes and transfer pricing issues, news out of Mexico today regarding a historic memorandum between the Mexican Senate and the San Diego Regional...
How will International Business Change in the Coming Months?
The question of the hour for many multi-national conglomerates and San Diego businesses with international distribution and supply channels is "How will international business change in the coming months?" The answer is surrounded in a cloud of Washington posturing and floated proposals. One thing seems certain: The United States Government...
Was the Caterpillar Raid a Sign of Where Corporate Tax Battles are Headed?
Really? That was my first reaction to the news that federal agents including the IRS had raided the offices of Caterpillar, one of America's greatest traditional companies. My next reaction was a bit more harsh, trending toward disgust. Is this a sign of where corporate tax battles are really headed?...
Caterpillar an Example of IRS Focus on International Business
Caterpillar has become an example of the IRS focus on international business and the aggressive tax planning strategies employed by multinationals in an attempt to shield income from US taxation. Just last week, the President loudly proclaimed "I love Caterpillar!" This week, their headquarters were raided by federal agents looking...
Border Tax Debate Heats Up
The border tax debate heats up as more and more business leaders descend on Washington to meet with lawmakers to express concerns. Speaker of the House Paul Ryan was quoted as saying "“[The border adjustment tax is] putting American-made products at a huge advantage. There’s a built-in bias in our...
GE Outsourcing Tax and Some Accounting A Good Model According to WSJ
An article this week in the Wall Street Journal noted General Electric (GE) had executed a strategy for outsourcing tax and some accounting services that other corporations are sure to follow. GE has decided to implement a "tax outsourcing" plan that will move internal employees to an external tax and...
New International Corporate Tax Discussions Unfold in US Congress
While new international corporate tax discussions unfold in the US Congress, American businesses brace for a tax scheme that could change some of the fundamentals of international business and associated Effective Tax Rates or ETRs. The majority party in Congress favors a "destination-based cash flow tax." Are we really moving...
A New World of Financial Transparency and International Tax
2017 is dawning on a new world of financial transparency and international tax cooperation between global sovereign tax authorities and the world's banks and investment houses. What does this mean for international investors, US taxpayers with offshore accounts and assets and international business? In short - a reckoning. The primary...
US Treasury and IRS Update Guidance on PFICs and CFC Investments
Recently the US Treasury Department and the Internal Revenue Service (IRS) released new guidance on PFICs and CFC investments for a Regulated Investment Company (RIC). Under US tax law a corporation can qualify as a Regulated Investment Company for a given tax year only when 90% or more of...