Kent P. Stackhouse’s Post

🚨Attention Business Owners, CPAs, and Attorneys!🚨 Navigating the Maze of IRS Compliance for Foreign Partnerships Just Got Easier! Educational Content: Are you involved in a partnership with foreign elements or transactions? It's crucial to understand your tax obligations to the IRS to avoid penalties and interest. Here's a quick breakdown: 1. Withholding on Foreign Partner’s ECTI: Partnerships must withhold taxes on income connected to U.S. business activities allocable to foreign partners, regardless of the partners' actual tax liabilities or distribution of profits. 2. FDAP Income: Tax must be withheld on a foreign partner's share of certain types of U.S. income, not connected to a U.S. trade or business. 3. FIRPTA Withholding: Purchasing U.S. real property from a foreign person? Your partnership might need to withhold taxes under FIRPTA. 4. Sale of Partnership Interest: Selling a partnership interest? There are specific withholding tax requirements, especially if the partnership is engaged in U.S. business. 5. FATCA Compliance: Partnerships may need to withhold taxes on distributions to foreign partners involving certain payments. 6. Coordination of IRC Sections 1445 and 1446(a): Understand how these sections interact, especially in real property interests and partnership gains. 7. Installment Payments and TINs: Ensure timely installment payments under IRC section 1446 and keep your foreign partners' TINs updated for tax return filings. Actionable Advice: Staying compliant can be complex but essential. Avoid the common pitfalls and stay ahead of your tax responsibilities. Call to Action: Don't navigate these tricky waters alone! For expert guidance on FINCEN and IRS compliances, contact our COO Anshul Goyal at [email protected] or visit our website www.kkca.io & schedule a meeting today. Ensure your business stays on the right side of tax laws! 📞💼📈 #TaxCompliance #IRSRegulations #BusinessGrowth #CPA #TaxPlanning #FIRPTA #FATCA #GlobalBusiness #PartnershipTax #FinancialSuccess

Understanding the Foreign Account Tax Compliance Act (FATCA)! Curious about FATCA and its implications for your business? My latest article, "What is The Foreign Account Tax Compliance Act (FATCA)," breaks down this important U.S. legislation and its impact on international financial operations. Learn how FATCA affects foreign financial institutions, reporting requirements, and compliance strategies to avoid penalties. Let's navigate the complexities of FATCA to ensure your business remains compliant and successful! #FATCA #InternationalTax #GlobalBusiness #TaxCompliance #BusinessStrategy

I am pleased to announce the publication of my latest paper on Exchange of Tax Information (#EoTI) on IBFD - #EuropeanTaxation Issue No. 8/2024. #Brexit has created unique challenges with respect to #EoTI and #AdministrativeCooperation between the United Kingdom and the EU Member States. In particular, the withdrawal of the United Kingdom from the European Union has led - among other things - to a departure from the #DACFramework, as well as from the #RecoveryDirective. To date, it remains challenging to define the future of administrative cooperation between the UK and the EU-MSs. However, as the UK government has confirmed its #OngoingCommitment to adhere to international standards on tax transparency and EoTI, any concern regarding a potential departure from these worldwide accepted "milestones" appears unfounded. The present analysis is divided into three main sections. The first provides historical and global context by defining the EoTI tools that were available in the pre-Brexit era. The second section briefly outlines the main features of the DAC directives, focusing - in particular - on the #CrossBrexit implementation of #DAC6. The third seeks to address certain current issues regarding the introduction of the #UK-MDR, and their relationship both with the former DAC6 framework and the domestic (UK) Disclosure of Tax Avoidance Scheme rules (DoTAS). I would like to extend my gratitude to my esteemed friend and colleague Captain Luca Scarano for our fruitful collaborative research on EoTI-related matters throughout recent years, and to Julie Rogers-Glabush and Angelika Xygka for their invaluable contributions and insightful feedback during the review of this paper. Full article available here: https://lnkd.in/daBpfPxZ Working Party on Tax & Legal Matters

OECD released updated information in terms of the International Compliance Assurance Programme (ICAP). The release has several relevant points but maybe the most interesting one is related to the posibility of using a Surrogate Lead Tax Administration. Meaning if a MNE has the UPE in a jurisdiction that is not participating at ICAP, the MNE may still have a chance of being included. This is relevant given the still rather limited number of jurisdictions part of ICAP. The programme should normally expend in the future as companies seek forms of certainty in a rather unstable environment. https://lnkd.in/e-3RGWMm

⭐ I'm excited to share that I recently co-authored an article about the increase in US state transfer pricing audits, which was published in the prestigious IBFD International Transfer Pricing Journal. This article dives into the rising trend of US state transfer pricing audits, analyzing the factors driving this increase and offering valuable insights for multinational corporations.   📖 "While the Internal Revenue Service has long scrutinized cross-border intercompany transactions, state tax authorities are increasingly focusing on state transfer pricing. This trend poses new challenges for company groups operating in multiple states. In states with separate tax reporting, each entity within an affiliated group is treated as a separate taxpayer for state income tax purposes, which can lead to profit shifting by manipulating transfer prices between affiliated entities in different states. In this regard, state tax authorities are taking a more proactive approach to examine and audit state transfer pricing positions. Recent significant state transfer pricing case law highlights the importance of preparing and maintaining adequate documentation to support intercompany transactions during state audits. Specifically, preparing an adequate transfer pricing study can be crucial for risk management by minimizing potential challenges from state tax authorities."   💻 Check out the full article here: https://lnkd.in/gzdAxN5e   ⭐ I'm immensely grateful for the opportunity to contribute to this important topic.   #transferpricing #ibfd #tax #beps #preciosdetransferencia #Latam

📝 Don't miss out our new article with the main topic of "OECD AND THE EU INITIATIVE TO SET A MINIMUM TAX RATE OF 15% FOR ALL EU MEMBER STATES", by Amkosource Services Ltd. 👇 For more interesting articles, visit our website on the link below: https://www.finhub.com.cy/ #finhub #buy #audit #firm #assurance #firm #buycompany #cyprus #acca #icaew #sellingpractise #buypractise #buypractice #sellpractice #lawyers #accountants #auditors #cyprusaudit #cyprusauditfirm #buy #looking #oecd #eu #initiative #minimum #tax #rate #EUmemberstate

The Pillar 2 compliance avalanche is gaining momentum MNEs with operations in Belgium must meet a strict 45 day-deadline to obtain a Pillar 2 registration number - anticipated deadline will be end mid-July - substantial information requiered Read Deloitte’s Tax Alert for more details #pillar2 #deloitte

🚨 FTA's New Rules for Changing Entity Types 🚨 Exciting news from the Federal Tax Authority (FTA)! Businesses can now seamlessly change their legal entity type—for example, shifting from a sole proprietorship to an LLC—without the hassle of deregistration and re-registration. This new amendment simplifies the process, making business transitions smoother than ever. Eligibility Criteria: Taxpayers can apply for this change under specific conditions, such as changes in business operations or incorrect registration. Note that this change is permitted only once. If you’re considering this transition, here are key points to keep in mind: ✅ Tax Compliance: Ensure that the new entity type aligns with your VAT and corporate tax obligations. ✅ Regulatory Alignment: Confirm your new entity type meets FTA requirements and relevant filing deadlines. ✅ Operational Impact: Review updates to trade licenses, invoicing, and contracts that may be necessary. This is a great opportunity for businesses to streamline their operations and adapt to changing needs, supporting growth and efficiency. Disclaimer: This post is for informational purposes only and is not a substitute for professional tax or accounting advice. Always consult a professional before making any decisions. #BusinessUpdates #FTA #TaxCompliance #BusinessRestructuring #VAT #CorporateTax #UAE

Stay ahead in this ever-evolving landscape of tax compliance with the March issue of the Comply Connect. This edition highlights important updates and insights for the month of March and into April, notably the new Form W-9 (Rev. March 2024) and the latest on Form 1099 updates, including new revisions and instructions for Forms 1099-K, 1099-B, and 1099-G. As regulations evolve and increase in complexity, staying informed is key to accurate data collection and timely filings. The March issue of the Comply Connect is here so that you have the knowledge and tools readily available. #Compliance #TaxCompliance #FATCA #CRS #IRSUpdates #Form1099 #W9 #Form1042S #TaxTechnology #ComplywithComply

Our #GCC #ITX News Roundup for Q2 2024 is now live. Read about the latest updates covering #VAT, #Excisetax, #Customs & #Trade, #RETT, #einvoicing and more. Key topics in this edition include the approval of the duty-free markets requirements, acceptance of ATA Carnets and the extension of #amnesty in the #KSA.In addition, we covered PwC’s active participation in a variety of events across the region. Get in touch for further information or if you would like to discuss how these changes impact your business. https://lnkd.in/dCqURJe2 PwC Middle East #tax #customs