US Tax Treaty Updates Japan and Spain

Posted by Sue Tuson on September 9, 2019

Sue Tuson

Long-awaited treaty protocols, signed in 2013, were finally ratified in July 2019. The protocol with Japan entered into force on August 30, 2019, provides amendments to the 2003 tax treaty. The protocol with Spain is due to enter into force on November 27, 2019, and provides for the amendments to the 1990 treaty.

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US Reporting of Foreign Subsidiaries

Posted by Sue Tuson and Teresa Gordon on August 28, 2019

The IRS continues to increase scrutiny of the reporting requirements applicable to foreign persons and U.S. companies with foreign transactions. It is important to fully understand these U.S. obligations because failure to report...


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Tax Reform Benefits for Corporate Exporters

Posted by Sue Tuson on April 24, 2018

The Tax Cuts and Jobs Act created a deduction for Foreign-Derived Intangible Income (FDII). The name of this deduction is misleading, it is actually a deduction against qualifying export income after a routine rate of return.


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Basics of an IRS Audit

Posted by Sue Tuson on February 2, 2018

When a taxpayer is notified by the IRS for a tax return audit, the first reaction may be panic or fear. Understanding the audit process …


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Cross-Border Taxation Update

Posted by Sue Tuson on May 25, 2017

The IRS announced 13 audit campaigns last March.  Included in the campaign is an effort to increase voluntary compliance for Form 1120-F Non-Filers.  Form …


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