Issuance of New Temporary Work Visas Suspended

By: Jennifer Dowdy Companies planning to hire foreign individuals to work in the U.S. may have their efforts stalled by President Trump's executive order suspending the grant of temporary employment visas.  President Trump issued the proclamation on June 22, 2020, and it immediately suspended the issuance of H-1B and H-2B, J and L temporary visas until December 31, 2020.  H-1B …

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GILTI High-Tax Exclusion: What You Should Know

By: Austin Yount and Goran Vukicevic The global intangible low-tax income (“GILTI”) regime was introduced under the Tax Cuts and Jobs Act of 2017 (“TCJA”). Under the old regime, US shareholders were not taxed on income earned by their controlled foreign corporations (“CFC”s) until those amounts were repatriated back to the US entity. This deferral syste…

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As the Global Economy Has Changed, Be Sure Transfer Pricing Follows

The ongoing pandemic’s effect on the global economy has the potential to upend transfer pricing policies for multinational companies. A company’s transfer pricing – which is how it prices intercompany transactions – is particularly vulnerable to a fluctuating and uncertain economy. As companies struggle with the unexpected economy of 2020, transfer pricing models ar…

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Reporting Payments to Foreign Persons – When Form 1099 Becomes Form 1042

By: Max Hattman Form 1042 is the withholding tax return for foreign persons with U.S. source income that is required to be filed annually, by March 15th. If you are a U.S. company paying a foreign contractor that is working within the United States, you are likely required to file this form, accompanied with a Form 1042-S, and withhold taxes on the payments made and remit them to the IRS.…

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The Impact of COVID-19 on Global Mobility and the Rise of Stealth Expats & Stealth Repatriations

By: Rebecca Fisher In light of the continuing global effects of COVID-19, individuals and businesses around the world are learning to navigate a new and ever-changing global mobility landscape. The world continues to witness border closures, travel bans, government closures & suspensions, stay-at-home orders, and frequent changes in government regulations.  As a result, companies…

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IRS Issues Further Clarification on Deductibility of Expenses Paid with Forgiven PPP Loans

By: Kim Kamens The week before Thanksgiving the IRS released long-awaited guidance regarding the tax treatment of expenses paid with PPP loan funds.  While we were all hoping for a reversal of IRS Notice 2020-32 released on May 2, 2020 on this topic.  Unfortunately that was not the case. The IRS issued a Revenue Ruling and a Revenue Procedure regarding the tax treatment of thes…

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Additional FAQs Provide Clarification on the PPP Loan Forgiveness Process, PPP, and EIDL Programs

By: Julie Dillon As we navigate these uncertain times, one of the areas on the forefront of the minds of many business owners is the Payroll Protection Program (“PPP”) forgiveness process. If you still have questions about PPP forgiveness, you are not alone. Additional clarification and new guidance continues to be published by the Small Business Administration (“SBA&rdq…

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Congress Passes PPP Extension

The U.S. Senate unanimously passed a five-week extension of the Paycheck Protection Program (“PPP”).  This news was announced late in the day on June 30th, which was the original deadline for taxpayers to apply for a PPP loan.  The U.S. House of Representatives joined the Senate in passing by unanimous consent and the bill now goes to President Trump, who is expecting…

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New Law Makes PPP Loans More Flexible for Borrowers

While many business owners scrambled to qualify for and receive a Paycheck Protection Program (“PPP”) loan, the realization set in that the loan period to use the funds was actually quite short, only an 8 week window, and came with significant reporting requirements. Some business owners were still waiting on funds as June approached, and the period to restore their workforce l…

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Transfer Pricing Is Trending

In the news Transfer pricing has become a top target for the IRS with the recent launch of multiple campaigns targeting alleged abuses in transfer pricing among U.S. taxpayers. In addition to the campaigns, the aggressiveness of the IRS on transfer pricing can be seen through some high-profile cases including, most recently, the suit against Facebook for $9 billion for unpaid taxes, inter…

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