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International Tax

tax evasion

Sins of the Father? Not Necessarily

July 25, 2019

Harry G.A. Seggerman, a pioneer in international investing, died in 2001, leaving an estate of $24 million dollars, with almost half of it undeclared in Swiss accounts. Seggerman never reported the foreign bank accounts during his lifetime, leaving it to... Read More


Proposed Regulations on Transfers by Foreign Partners

June 21, 2019

Partnerships Doing Business in U.S. Must Withhold Tax When Foreign Partner Leaves When Congress moved the U.S. to a modified territorial tax system, it also put in place compliance measures designed to make sure that income generated within U.S. borders... Read More

Tax Implications of Brexit-related Transfers of Marketing Authorisations

June 5, 2019

On 9 April the European Medicines Agency updated their guidance on the impact of Brexit for the pharmaceuticals sector in Europe. Understandably the main concern continues to be on the continuity of supply for existing drugs, but the guidance emphasises... Read More

Untangling the Technical: Expanding to the UK: Understanding the Landscape

May 16, 2019

The UK is the fifth largest economy in the world, and its stated goal is to be business friendly from a tax perspective. Join two international tax experts to learn about some of the tax implications of expanding to the... Read More

Untangling the Technical: Making the jump to the US: What UK companies need to consider

April 8, 2019

The US is an enormous market that offers tremendous opportunity. Recent changes to the American tax code make this market even more attractive, but there are still many differences that are important to understand when considering expansion into the US.... Read More

Untangling the Technical: Breaking Down Brexit: On the Brink

March 21, 2019

In less than two weeks the UK is supposed to leave the EU. Join Malcolm Joy, the Lead Partner of our London office, and Mike Whitacre, one of the leading partners in our International Tax Practice as they discuss the... Read More

Untangling the Technical – New International Tax Law Implications

April 30, 2018

The complicated new rules for multi-national businesses were one of the headlines of the new tax law. In this episode, Frazier & Deeter’s International Tax guru Mike Whitacre discusses the implications for U.S. businesses with foreign earnings as well as foreign companies... Read More

IRS Waives Estimated Tax Rules, Penalties on Deemed Repatriation

April 24, 2018

The IRS has rushed out yet another guidance document on the Tax Cuts and Jobs Act’s deemed repatriation rules for offshore profits. Notice 2018-26 includes rules on penalty waivers, special elections, and the mechanics of reporting and paying the transition... Read More

Repatriation of Corporate Profits a Priority for IRS

March 23, 2018

Tax Bill Guidance Continues to Focus on Repatriation In the few months since the Tax Cuts and Jobs Act (TCJA) was signed into law, the IRS has released three important items of guidance relating to the transition tax on foreign... Read More

The Bank Is Open: IRS Tells Corporations How to Pay Tax on Offshore Profits

February 27, 2018

The first topic the IRS tackled in guidance regarding the new tax law is how corporate taxpayers should compute and pay the “transition tax” on the untaxed earnings of foreign subsidiaries. In exchange for the lower 21% corporate tax rate... Read More