Cross-Border M&A: Section 338(g) Elections After TCJA

338(g) Elections at a glance Schedule a consultation today 338(g) election – the full story: When exploring avenues to grow their business, a U.S. corporate taxpayer may expand offshore by purchasing a foreign business. Similar to a domestic acquisition, an initial structuring question the taxpayer must address is whether to purchase stock or assets of…

Read More

International Tax Considerations for Distributions From Foreign Corporations

At a glance: The Main Takeaway: U.S. taxpayers who are repatriating cash from foreign operations must appropriately consider complex federal international tax requirements. Impact on Your Business: There are important considerations taxpayers should think through before starting the repatriation process to ensure they don’t have an unexpected material tax consequence. Next Steps: Enlist the help…

Read More

4 Tips to Fuel Your International Business’s Post-Pandemic Growth

At a glance: The main takeaway: The business world will look vastly different after COVID-19, which means international businesses will need to re-examine their activities to remain competitive. Impact on your business: Business areas such as employee relations, hiring, customer preferences and risk management will all be affected post-pandemic. Next steps: Be proactive and better…

Read More

Webinar: How to Benefit From the New COVID Relief Package

The American Rescue Plan Act of 2021 provides additional relief to address the continued impact of COVID-19 on the economy. Watch the webinar hosted by Aprio and the Belgian American Chamber of the South, to gain a better understanding of the significant tax provisions available to both individuals and businesses, plus ways you can leverage…

Read More

Top 5 Things You Need to Know About The Business Interest Deduction Limitation and Controlled Foreign Corporations

At a Glance IRS Final Regulations Update: The IRS released final regulations on the business interest deduction limitation that directly impacts controlled foreign companies (CFCs). Impact on Your Business: The final regulations bring more clarity and potentially bring more challenges for CFCs and their U.S. shareholders. Next Steps: You need to assess your CFC interest…

Read More

The Wonderful World of OZ: What Proposed Regulations on Opportunity Zones Mean for You

At a Glance: International Investors, Take Note: The IRS and Treasury have proposed new regulations regarding the requirements around opportunity zones, specifically as they relate to non-U.S. investors and foreign-owned partnerships. What’s the Impact? The opportunity zone regime is intended to be a helpful economic development tool, so these new rules could have a significant impact on…

Read More

IRS Final Regulations on Foreign Tax Credits: New Compliance Headaches

At a Glance: IRS Final Regulations Update: The IRS has released the long-awaited final regulations for foreign tax adjustments, which the Tax Cuts and Jobs Act (TCJA) significantly reformed in 2017. Impact on Your Business: The new rules expand the definition of a foreign tax redetermination and introduce additional compliance obligations for U.S. taxpayers. Next Steps: Failing to…

Read More