Seattle International Tax Attorney Blog
Law firm of Harlowe & Falk LLP
The IC-DISC (“Interest Charge Domestic International Sales Corporation”) regime provides a two prong tax incentive to U.S. based companies exporting product for use outside of the United States. This blog post covers the basic concepts of the IC-DISC tax regime, found within Code Sections 991 - 997 of the Internal Revenue Code and the accompanying...
As implimentation of the Foreign Account Tax Compliance Act ("FATCA") continues, U.S. persons with offshore financial accounts are beginning to take notice. Passed as part the 2010 HIRE Act, FATCA's goal is to increase offhsore account compliance. FATCA provides a two prong attack on offshore accounts. First, FATCA creates a new...
The IC-DISC (“Interest Charge Domestic International Sales Corporation”) has been a powerful tax incentive supporting US businesses who sell products which are ultimately exported. As the fiscal cliff drama unfolded toward the end of 2012, many in the international tax community wondered whether IC-DISC benefits remain. Thankfully...
Once IC-DISC eligibility is determined, careful thought should be given in determining which state the IC-DISC should be incorporated. One important factor in determining the state of incorporation should be state and local tax laws. Based on Washington State’s apportionment rules, and a recent ETA provided by....
Enacted as part of the 2010 HIRE Act, The Foreign Account Tax Compliance Act (“FATCA”) is an important development in U.S. efforts to improve tax compliance involving foreign financial assets and offshore accounts. FATCA’s approach to foreign financial account compliance is twofold. First, U.S. taxpayers with...
RECENT TAX CUTS AND JOBS ACT ARTICLES
IRS Publishes Guidance on Application of Section 965 for 2017 Tax Year Filings
The Interest Charge Domestic International Sales Corporation ("IC-DISC") after the Tax Cuts and Jobs Act
International Tax Law Changes - A Look at the CFC Attribution Rules after the Tax Cuts and Jobs Act
RECENT INTERNATIONAL TAX ARTICLES
Court Reviews Reasonable Cause Standard in Recent Case
Willful FBAR Penalty Against Taxpayer Sustained
FBAR Penalty in Excess of $100,00 allowed where multiple counts of FBAR violations
IRS Announces New Voluntary Disclosure Program for Delinquent International Filings and Foreign Bank Accounts
FBAR Penalty Does Not Terminate at Death
IRS Provides Guidance on Standard for Definition of Willfulness under FBAR
IRS to end Offshore Voluntary Disclosure Program "OVDP"
Definition of "Willful" in FBAR and OVDP Context Examined by Recent Court Case
Streamline Offshore Filing Procedure - Application of the Non-Residency Rules to Taxpayers with Foreign Bank Accounts
Tax Court disallows Section 911 Exclusion due to late filing
Key Differences Between FBAR & FATCA Filing Requirements
Tax Court Revisits Definition of "Abode" under Section 911 in Recent International Tax Case
PFIC Filing Requirements, Who Must File PFIC Form 8621 & For What Tax Years
UPCOMING AND RECENT INTERNATIONAL TAX PRESENTATIONS
University of Washington - UW T523 - International Estate Planning
Panelist: Washington Society of Certified Public Accountants, International Tax Conference 2018
Panelist: Foreign Personal Holding Company Income Reporting: Mastering Subpart F Inclusions and Deemed Dividend Rules
Panelist: Form 8621 PFIC Reporting: Navigating the Highly Complex IRS Passive Foreign Investment Company Rules
Presentation: Basics of International Tax Planning for Attorneys and CPAs
Bloomberg BNA: International Taxation of Computer Software under Reg. Sec. 1.861-18 & Cloud Computing Transactions
UPCOMING AND RECENT INTEREST CHARGE DOMESTIC INTERNATIONAL SALE CORPORATION (IC-DISC) PRESENTATIONS
University of Washington - International Estate Planning - Tax LLM Program - UWT523
IC-DISC Tax Planning - Estate Tax Benefits - Estate Planning Council Presentation
IC-DISC: Tax Law Challenges
Bloomberg BNA - How to Reduce Tax Obligations Using IC-DISCs - for attorneys and CPAs
IC-DISC Tax Planning - Life after Summa Holdings v. Commissioner
Panelist: IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Federal Tax Savings
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Mehrdad is a partner at the law firm of Harlowe & Falk LLP. Based in the greater Seattle area, but with clients internationally, Mehrdad's practice includes international tax consulting. This includes consulting with clients on inbound transactions, outbound transactions, mergers & acquisitions, and IC-DISC....