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Final IRS Anti-Hybrid, Other Proposed Regulations Impact Cross-Border Structures
Earlier this year, the IRS published final anti-hybrid regulations (T.D. 9896) under sections 245A(e), 267A, and 1503(d) and new proposed regulations under sections 245A(e) and 881. The...
UPDATE: Employee Payroll Tax Deferral
During a payroll tax industry telephone conference on September 3rd, the Internal Revenue Service commented on many issues related to President Trump’s Executive Order which permitted the...
Final Section 245A Regulations Deny the Dividends Received Deduction in Certain Transactions
Effective August 27, the Treasury and IRS have finalized (T.D. 9909) temporary and proposed regulations, originally issued last year under section 245A, that treat as taxable dividends (not...
IRS Provides Guidance on Executive Order Deferring Payroll Tax Obligations
On August 8, 2020, President Trump issued an executive order to defer withholding, deposit and payment of the employee portion of Social Security taxes on wages paid between September 1,...
IRS Finalizes GILTI-High Tax Exclusion
On July 20, the Internal Revenue Service (“IRS”) published final global intangible low-taxed income (“GILTI”) high-tax exception regulations (T.D. 9902) under sections 951A and 954...
Mazars Private Client Services for NextGen: Thinking Outside the Box, Episode 13
Description Creative Artist and Designer, Alicia Noelle Jones, founder of ANoelleJay showcases her passion for the environment using art. She paints whimsical snapshots of the earth and...
The Complexities of Foreign Trust Reporting
Foreign trusts have been a topic of increased scrutiny in recent years and can be traps for the unwary. In fact, on May 21, 2018, the IRS Large Business and International Division added...
Revenue Recognition Procedure Changes Food & Beverage Companies Should Watch Out for Due to ASC 606
In May 2014, the Financial Accounting Standards Board (FASB) issued a new accounting standard which changed the way revenue is recognized and disclosed in financial statements. Accounting...
I Never Report My Foreign Assets! Help!
A US individual is required to report their worldwide income and foreign financial assets, including foreign bank accounts to the US Government; however, many US taxpayers are not aware of...
