Foreign Tax Credits Explained: How to Limit Exposure to Double Taxation on Cross-Border Income
I. The Double Taxation Dilemma: Why the FTC Is Your Global Shield For any U.S. person earning income abroad, whether through a foreign rental property, a cross-border business, or international investments, the threat of double taxation is a constant reality. The United States imposes tax based on citizenship and residency, meaning U.S. citizens and resident […]
How Transfer Pricing Rules Can Affect Your Global Supply Chain
I. The New Era of Supply Chain Management: Tax as an Operational Driver For decades, multinational corporations managed their supply chains based almost exclusively on logistics, labor costs, and proximity to markets. Tax considerations were often an afterthought—a final “refinement” made by accounting teams after the physical infrastructure was already in place. However, in today’s […]
GILTI, BEAT, and FDII Explained: Key U.S. International Tax Changes for Multinationals
I. What Are GILTI, BEAT, and FDII? Since 2017, the trio of GILTI, BEAT, and FDII has served as the backbone of the U.S. international tax regime. Originally enacted under the Tax Cuts and Jobs Act (TCJA), these provisions were designed to balance two competing objectives: discouraging U.S. companies from shifting profits to low-tax jurisdictions […]
When an IRS Audit Becomes a Legal Problem
Article Overview: For most taxpayers, an IRS audit is a financial annoyance—a review of deductions, credits, or income reporting. But when the inquiry shifts from “how much do you owe” to “did you intend to deceive,” a civil examination can evolve into a criminal legal problem. Understanding the warning signs of an IRS fraud referral […]
Tax Residency Rules: Key Considerations for Non-U.S. Individuals and Businesses
I. The Global Grid: Why Residency is Your Most Critical Choice In the modern era of remote work and globalized commerce, the concept of “residency” has evolved from a simple physical presence into a complex legal determination. For many, the choice of tax residence is the single most important decision in a wealth preservation strategy. […]
Christine Concepción Featured on The Scholar Wealth Podcast
On his podcast, The Scholar Wealth, host Stephan Shipe was joined by Christine Alexis Concepción, Esq. to examine how families think about cross-border living, tax exposure, and long-term planning when life extends beyond just one country. The following is a transcript from the podcast. Listen to the entire podcast here. From the Field – Cross-Border […]
Corporate Transparency Act Update: Unenforceable Against Only Certain Businesses
Background In 2021, Congress enacted the Corporate Transparency Act (“CTA”) as part of an anti-money-laundering initiative. The CTA mandates that all entities formed or registered to do business in the US (“Reporting Companies”) and all foreign entities registered to do business in any state, unless exempt, must disclose their beneficial ownership to the Department of […]
IRS’s New Tax Amnesty Program: Voluntary Disclosure Program for questionable Employee Retention Credits
On December 21, 2023, the Internal Revenue Service announced a new Voluntary Disclosure Program (the “ERC VPD”) to assist taxpayers who want to pay back the IRS after having erroneously filed for Employee Retention Credits (the “ERC”). The IRS is also urging employers to withdraw pending ERC claims in a separate program that allows them […]