Subpart F: Taxation of Foreign Income Earned by U.S.-Controlled Foreign Corporations

Posted on by Moskowitz LLP Business Law, International Taxation,
In 2012, Google made headlines when it was revealed that the multinational company had avoided approximately $2 billion in worldwide income taxes the previous year by funneling the equivalent of 80% of the company's pre-tax profit through a Bermuda shell company. The tax avoidance techniques used by the company (the...
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Crackdown on Tax Treaty Abuses

Posted on by Moskowitz LLP Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance,
Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in the international tax system, there is a growing concern that they not only...
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Corporate Inversion – Assertive Tax Planning & Political Concerns

Posted on by Moskowitz LLP Business Law, Tax Planning & Compliance,
Our recent article published, The Corporate Inversion: From Obscure Strategy to Hot Trend addresses why many businesses and longstanding American icons have made the move towards corporate inversion, a tax reduction method of re-incorporating a company in another country if a significant portion of the company's income is derived from...
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The Corporate Inversion: From Obscure Strategy to Hot Trend

Posted on by Moskowitz LLP Business Law, Tax Planning & Compliance,
Capitalist ideals of “free enterprise” and “competition” make great debate topics, but when compared to the business-friendly tax codes of other nations the United States Tax Code cannot compete. With the highest corporate income tax rate in the developed world, many businesses and longstanding American icons have made the move...
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Tax Inversions: Tax Savings Strategies for Corporations and What Political Calls for Tax Reform Mean

Posted on by Moskowitz LLP Business Law, Tax Planning & Compliance,
Corporate inversion is defined as an international corporation reincorporating in a different country, changing from a U.S. corporation to an offshore jurisdiction that is usually a tax haven and therefore potentially reducing tax liability. U.S. Corporations have availed themselves to the policy and have reaped the rewards of lower tax...
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IRS Targets: Tax Audits of Partnerships, LLCs, and other Pass-through Entities

Posted on by Moskowitz LLP Business Law, Tax: Audits, Litigation & Collection,
The Internal Revenue Service announced on November 7, 2013, that it intends to make auditing and examining partnership and other pass-through entities, such as LLCs, S-Corporations, and sole proprietorships a top priority in 2014.  This comes after years of targeting corporations for exam. Pass-Through Entity returns are subject to the...
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