Tags » International Tax

6662(e) penalties and the decision to file contemporaneous documentation


This entry aims to provide a discussion of how a taxpayer would approach the decision of preparing contemporaneous transfer pricing documentation.  This entry assumes that the taxpayer’s transfer pricing analysis and policies are compliant with the reasonable cause and good faith exception of 26 CFR 1.6664-4. 455 more words

International Tax

Valuable facts on US Taxes: One Year Abroad

Prior to moving, everyone from our accounting friends, to the UK Government, prepared us for terror regarding being US citizen abroad.

We received countless articles warning us about double-taxing, paying our taxes later and general traumatic Reddit post about someone abandoning their US citizenship to avoid tax penalties. 1,028 more words


Yes, Minister

Looking confused next to the overhead locker of my assigned Business Class seat on a British Airways flight from Heathrow to New York last year, I was approached by a helpful flight attendant (if that is what stewardesses are called these days) who offered assistance. 538 more words

International Tax

Some like it hot

Political fossil Al Gore’s sequel to his Oscar winning environmental documentary ‘An Inconvenient Truth’ – ‘An Inconvenient Sequel’ – may have underwhelmed at the box office this month, but it provided a timely counterweight to President Donald Trump’s announcement some weeks earlier that the United States was pulling out of the Paris Agreement. 450 more words

International Tax

Brother, can you spare a dime?

He is best remembered through the prism of the witticisms of his arch-rival, Winston Churchill: ‘A modest man, who has much to be modest about’; ‘A sheep, in sheep’s clothing’; ‘Up drew an empty taxi, and out stepped…’, but Clement Attlee, the fiftieth anniversary of whose death is being marked this year, had many arrows to his bow. 470 more words

International Tax

The Multilateral Instrument and the future of bilateral tax treaties

Tax treaties are based on a set of common principles designed to eliminate double taxation that may occur in the case of cross-border trade and investments. 1,047 more words

Direct Tax

There is an i in America

In a sweltering, politically incorrect scene in Raiders of the Lost Ark, Indiana Jones – tired of the boastful swordsmanship of an Arab adversary – nonchalantly draws his pistol and shoots him dead. 420 more words

International Tax