International
U.S. Government Contractors and Cross-Border Payroll Tax Issues
The cross-border global expansion of business activities continues to increase exponentially in the US government contracting industry. Many government contracting…
Yelena Epova as a special guest on “Business Radio X” podcast
Listen to the podcast here! Yelena Epova is the partner-in-charge of the international tax services at Aprio. She specializes in advising domestic and…
New Form 5472 Filing Requirement for U.S. Disregarded Entities Owned by a Foreign Person
On December 13, 2016, the IRS issued new regulations (T.D. 9796) that requires U.S. disregarded entities owned by a foreign…
New Controlled Foreign Corporation Constructive Ownership Rule
The Tax Cuts and Jobs Act enacted in December 2017 changed a constructive ownership rule that determines whether a foreign…
Avoid Penalties Related to International Tax Filings
The IRS Large Business and International Process Unit (LB&I) issues internal practice guidance from time to time regarding U.S. international…
Commercial Service Spotlight –Going Global Strategically
At a glance: Main takeaway: Are you a small business or startup with plans for global expansion, but not sure…
Look-Through Rule Under I.R.C. Section 954(c)(6) Is Extended
The President signed The Tax Increase Prevention Act of 2014 on December 19, 2014. The new Public Law No. 113-295 (H.R….