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International

Thursday, 25 July 2019

Leverage locality to grow globally

Written by Chip Hoebeke, CPA, CIRA, Fellow INSOL International and John Pridnia, CPA, CGMA

Global growth can accelerate business value quickly. Between new revenue streams, larger pools of talent, increased finance opportunities and more — international expansion can vault a business to new heights. But just as venturing into any new territory, global growth can be filled with unknowns. So, if your business wants to grow, seek as many inroads as possible into new markets...

Tuesday, 21 November 2017

Do you know where your business is?

Written by Michael Bannasch, CPA, MST

Where is your business located? This question may seem straightforward, but when it comes to state and local taxes, answers — and borders — can start to blur. Consider the following scenario: A debt collection agency located in Michigan was seeking to grow and willing to find that opportunity anywhere in the U.S...

Thursday, 27 April 2017

Gearing up for the future: 6 ways to bolster your tax-planning toolkit

Written by Michael Patterson

International tax professionals and business owners might feel apprehensive about how to proceed in a climate in which change is certain, but the details have not yet come into focus. A proposed 20-point decrease in the corporate tax, a repatriation tax, a border adjustment tax and an end to interest deductibility could mean sweeping changes to how multinational companies conduct their businesses. How can one prepare in the face of such uncertainty? By incorporating concepts known to remain relevant — regardless of the outcome of proposed legislation — into your repertoire of tax planning resources...

Tuesday, 03 November 2015

EU countries agree to swap tax-ruling data

Written by Thomson Reuters

The European Union (EU) member states unanimously agreed to automatically swap information on cross-border tax rulings. Under the new rules, the countries would be required to swap the data every six months. The new rules will remove EU Member States' discretion to decide what information is shared, when and with whom. The exchanges would also cover existing rulings of the past five years...

Tuesday, 03 November 2015

Final BEPS measures sent to G-20 heads of state

Written by Thomson Reuters

G-20 finance ministers endorsed the final package of measures for a comprehensive, coherent and coordinated reform of the international tax rules. The ministers expressed strong support for the OECD/G-20 Base Erosion and Profit Shifting (BEPS) project. BEPS provides solutions for closing the gaps in international rules that allow corporate profits to be shifted to low- or no-tax countries, where little or no economic activity takes place. "Base erosion and profit shifting is sapping our economies of the resources needed to jump-start growth, tackle the effects of the global economic crisis and create better opportunities for all," said Angel Gurría, Secretary-General of the Organisation for Economic Cooperation and Development (OECD)...

Monday, 05 October 2015

Foreign tax law changes affecting investors

Written by Thomson Reuters

China and India have announced tax changes that affect investors. China announced that dividend income that certain individual shareholders receive on shares of Chinese companies will be exempt from personal income tax. In a separate announcement, India said that the minimum alternative tax (MAT) would not apply to certain foreign institutional investors (FIIs) and foreign portfolio investors (FPIs). Troubled Chinese stock markets The Chinese measures are the latest in a series of moves Beijing hopes will encourage longer-term investment and halt a slide in Chinese equities...

Monday, 05 October 2015

BEPS: G-20 finance ministers to monitor cross-border tax rulings

Written by Thomson Reuters

G-20 finance ministers and central bank governors recently committed to monitoring the outcome of the base erosion and profit shifting (BEPS) project, particularly when it comes to the exchange of information on cross-border tax rulings. BEPS is a project of the Organisation for Economic Co-operation and Development (OECD) that brought together OECD nations as well as additional countries that supposedly all participated on an "equal footing" in the development of the BEPS measures. Call for an OECD framework In a communiqué highlighting the actions required to achieve the international forum's goals for this year, the G-20 leaders said: "We call on the OECD to prepare a framework by early 2016 with the involvement of interested non-G-20 countries and jurisdictions, particularly developing economies, on an equal footing." They added that they welcomed the efforts by the International Monetary Fund, World Bank Group, United Nations, and the OECD to provide technical assistance to interested developing economies in tackling the domestic resource mobilization challenges they face, including from BEPS...

Monday, 05 October 2015

IRS targets income shifting through improper transfer pricing

Written by Thomson Reuters

The IRS recently issued an international practice unit (IPU) showing its examiners how to search for potential income shifting when auditing outbound sales of tangible goods by U.S. units of multinationals. Specifically the guidance targets sales to foreign affiliates where the price of tangible goods fails to reflect U...

Friday, 04 September 2015

New Zealand: Proposal to apply GST to cross-border services and intangibles

Written by Thomson Reuters

The New Zealand government has issued a discussion document about imposing a goods and services tax (GST) on the cross-border supply of services and intangibles. This would include e-books, music, videos and software purchased from offshore websites. The proposed rules would require offshore suppliers to register and return the GST when they supply services and intangibles to consumers who are residents of New Zealand. The destination principle New Zealand’s GST is a “consumption tax” — a tax on consumer spending on goods and services...

Friday, 04 September 2015

IRS issues interim guidance for expatriate health plans regarding the ACA

Written by Thomson Reuters

The IRS recently issued interim guidance in Notice 2015-43 related to how the Affordable Care Act (ACA) applies to expatriate health plans. Previous guidance exempted certain expatriate health plans from some ACA provisions. Then, a law enacted in December 2014 codified the exemption of qualifying expatriate plans issued or renewed on or after July 1, 2015, from most ACA requirements — provided they met specified standards. Now that the July 1 effective date has passed without interpretive guidance, the recent IRS notice generally allows application of a “reasonable good faith interpretation” of the standards until further guidance is issued...

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