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Are Your Non-U.S. Executives Prepared For U. S. Estate Tax?
Many multinational companies have non-U.S. citizen executives working in the United States. Although usually limited to three or four years, these assignments may continue for an extended period, such that the executive and his family establish strong ties to, and acquire substantial assets in,...
Read MoreTax Insights from Roberts & Holland LLP Is Evading Foreign Taxes A U.S. Crime?
Most tax practitioners are fully cognizant of their duty to ensure that their U.S. tax planning activities don't cross the line from permissible tax minimization into the unethical and sometimes illegal territory of tax evasion. However, when tax practitioners acting on behalf of multinational...
Read MoreIRS Shines Spotlight On Executive Compensation Practices
The Internal Revenue Service has undertaken a new initiative to verify that income and employment tax requirements relating to executive compensation are being complied with by both corporations and their top executives. It recently released a series of Audit Technique Guides (Guides) to be used...
Read MoreHow Many Tax Opinions Will You Need: And Where Will You Get Them?
The American Jobs Creation Act of 2004 (the "Act"), which provided and extended many corporate tax benefits, also introduced onerous new rules limiting the ability of taxpayers to rely on "tax opinions" to avoid penalties. Background The Internal Revenue Code (the "Code") has long contained...
Read MoreShould Accounting Firms Be Tax Advisors?
That is the burning question being addressed anew, this time by the Public Company Accounting Oversight Board ("PCAOB"). PCAOB was created under the Sarbanes-Oxley Act of 2002, to oversee financial reporting by public companies and establish standards relating to the ethics and independence of...
Read MoreA One-Time Tax Break For U.S. Multinationals
By some estimates, U.S. multinationals have accumulated in foreign subsidiaries as much as $500 billion of income untaxed by the United States. This income, which was earned from overseas business operations, would not ordinarily be subject to U.S. tax until the foreign subsidiaries distribute it...
Read MoreA Tax Opinion Is Not A Bulletproof Vest
Perhaps at some point you have secured a "tax opinion." The reasons for doing so vary, but usually involve a significant transaction. Often there is not enough time to get an advance ruling from the IRS as to the tax treatment of the transaction. Sometimes the law is unclear or the positions of the...
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