Meet the Co-chairs - TIAG
Mercer & Hole
Cohen & Company (Ohio)
Fineman West & Co. LLP
Meet the Co-chairs - TAGLAW
Williams Mullen (VA)
Contact: Lee Zimet of Berdon LLP (New York, New York, USA - TIAG)
The U.S. Bureau of Economic Analysis (BEA) recently imposed new filing requirements on U.S. persons with foreign affiliates. The BEA is an agency of the U.S. Department of Commerce. In an effort to secure current economic data on foreign affiliates, the BEA has mandated Form BE-10 filings by certain U.S. persons once every five years. These forms were previously only required if a U.S. person was contacted directly by the BEA.
Contact: Ray Polantz, Cohen & Company (Ohio, USA)
America is the land of opportunity. However, opportunity can mean additional tax considerations, especially for foreign individuals setting up a business on U.S. soil. It is imperative to structure the business appropriately from the beginning so as not to trigger any unintended U.S. tax consequences down the road. Below is a brief comparison of the most popular entity structures to consider.
Asian investors can minimize the tax hit on property purchases but good advice and a lot of paperwork is needed.
Maury Golbert of Berdon LLP (New York, New York, USA), was recently featured in an article on Barons.
If you live in Hong Kong and want to buy a home in Palo Alto for your daughter while she goes to Stanford University, you have a lot more to think about than finding a nice neighborhood. That's because buying U.S. property places you squarely in the U.S. tax system, adding big costs to your purchase.
That's hardly surprising news if you're from the U.S., but it's a shock to lots of non-U.S. residents. "If you are coming from a low-tax or no-tax jurisdiction, that is not the opening question ...it comes up as an after-thought," says Maury Golbert, chair of the real estate services group at Berdon, a New York accounting firm. "That's a dangerous proposition for a number of reasons."
Following up with the VAT reform launched in 1 August 2013 nationwide, to further include more industries into the Business Tax (BT) to Value Added Tax (VAT) transformation pilot program (VAT pilot program), in year 2014, the Ministry of Finance and the State Administration of Taxation have jointly announced a series of circulars to promulgate that postal services, railway transportation as well as the telecommunication services are covered in the VAT pilot program.
Contact: Teri Grumski; Cohen & Company (Ohio, USA)
The IRS issued new proposed regulations on January 20, 2015. These regulations are intended to provide guidance on how internally developed software applies to the R&D tax credit.
Generally in regard to the R&D credit, research with respect to computer software developed by the taxpayer primarily for internal use is not considered qualified research. However, it can qualify if the software meets certain conditions. The proposed regulations continue to stress (and further expand on) these conditions, but the proposed regs also further define internal use software and provide rules and a safe harbor for dual-function software.