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International Tax

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

New Tax Law a Game-Changer for Corporations

January 26, 2018

Reducing the high U.S. corporate tax rate was a key driver for enacting the Tax Cuts and Jobs Act (TCJA), Public Law 115-97. The most significant change is the reduction in the corporate tax rate to 21% from 35% and... Read More

IRS Launches Country-by-Country Reporting Tool

August 25, 2017

Countries across the globe banned together a few years ago to put in place a mechanism for tracking the income of multinational companies in each country in which they operate. The effort came under the umbrella of the very bureaucratic... Read More