Podcasts about subpart f

By Adam Turteltaub There isn't one way to handle conflicts of interest. Much depends on the research the organization is doing, its history and other systems. Hilary Kitson, Research Compliance Business Partner at Saint Luke's Health System, reports that typically the starting point is Title 42 PART 50 Subpart F in the Code of Federal Regulations. It lays out time points when disclosures are necessary: Annually When discovering or acquiring a new financial conflict of interest (COI) At the time of application for PHS-Funded research Disclosures aren't enough, though. There needs to be investigators and a review committee who are competent to examine potential conflicts and are sensitive to the confidentiality of the information involved. And what if there is a conflict? She advises involving regulatory and other professionals who can help develop a management plan, if one is necessary. Listen in to learn more about the very complex issue of conflicts of interest in research.

Join Toby Mathis, Esq., as he speaks with international tax expert Jimmy Sexton, LLM., the Founder & CEO of Esquire Group, about unraveling the enigma of offshore banking and its impact on US taxpayers. Despite popular belief, Jimmy reveals that the era of offshore banking providing substantial tax benefits is over, with the true perks lying elsewhere such as asset protection and market access. We navigate through the murky waters of tax evasion myths and scrutinize how various income structures, including disregarded and taxable entities, bear on one's tax obligations. Moreover, Jimmy illuminates the effects of the GILTI and Subpart F tax regimes on foreign company profits, stressing the importance of understanding the intricate US tax code to avoid hefty penalties and ensure compliance. Highlights/Topics: Offshore banking myths vs. reality for US taxpayers Tax advantages from asset protection, not tax savings Misconceptions about offshore tax evasion Implications of GILTI and Subpart F tax regimes Complexities of international business operations Benefits of Foreign-Derived Intangible Income (FDII) Major corporations adapting to tax law changes- Google and Amazon Tax reforms encourage repatriation and competitiveness Severe penalties for non-compliance with FBAR regulations Compliance demands of offshore structures versus domestic Corporate Transparency Act and international standards Resources: Esquire Group http://www.esquiregroup.com/ Email the Esquire Group info@esquiregroup.com Call the Esquire Team: UAE: +971 4 517 8458 | US: +1 480 525 4829 Learn Next Level Passive Income Strategies Through Real Estate Investing https://infinityinvesting.com/infinity-investing-workshops/ Tax and Asset Protection Events https://andersonadvisors.com/real-estate-asset-protection-workshop-training/?utm_source=aba&utm_medium=podcast&utm_content=how-do-offshore-corporations-and-trusts-work-in-the-us Toby Mathis on YouTube https://www.youtube.com/c/tobymathisesq Anderson Advisors https://andersonadvisors.com/  

A reading of the Federal Aviation Regulations - Part 61: Subpart F. Go premium at: www.wificfi.com to study ad free, download all course content, access all lesson quizzes, view and print the full flight syllabus, access and download all study tools, take FAA practice written tests, earn your Written Test Endorsement, and customize your lessons and lesson plans!Support the show

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC Value Chain Transformation Specialist Tom Quinn. They discuss the Sixth Circuit Court of Appeals ruling to uphold the US Tax Court's May 5, 2020 decision, and concluded that a CFC's income ‘attributable to' a branch, in this case a manufacturing branch, per se is foreign based company sales income (FBCSI) under the statute if a ‘substantial tax deferral effect' is found. They specifically discuss the Maquilladora structure, FBCSI, a ‘substantial tax-deferral effect', the Court's interpretation of the branch rule, and future implications for other taxpayers.Note: Since the recording of this podcast, the US Court of Appeals for the Sixth Circuit denied Whirlpool's request for a rehearing. Whirlpool has 90 days from March 2, 2022, to petition for certiorari with the US Supreme Court.

In this episode of the SALT Shaker Podcast, Eversheds Sutherland attorneys Nikki Dobay and Chris Lee discuss a recent Oregon Tax Court decision addressing whether Subpart F income and dividend income included in the Oregon income base should also be included in the Oregon apportionment sales factor. They also discuss how this decision may impact the apportionment treatment of Section 965 deemed repatriation income and GILTI. For a link to the case discussed in the episode, click here.  Questions or comments? Email SALTonline@eversheds-sutherland.com.

If you are a U.S. citizen and 10% stockholder of a foreign company, the foreign company is classified as a Controlled Foreign Corporation (CFC). If the CFC is paying you for services or distributing dividends, such payments received will be classified as Subpart F income. Subpart F is very complicated and needs to be analyzed in great detail to prevent unintended consequences. In this article, we endeavor only to provide you with a brief synopsis of the issues you have to take note of and discuss with your tax professional. From the outset it is important to take note: Subpart F income DOES include passive income. Any foreign investment you might have that is making a passive income for you in the current financial year, will in all probability be deemed to be Subpart F income and be taxable even if it is not distributed. So What Are A Controlled Foreign Corporations? Not all foreign investments nor all foreign corporations are automatically defined as “controlled foreign corporations.” A Controlled Foreign Corporation is defined by law as a corporation with more than 50% U.S. ownership in which individual U.S. persons each own at least 10% of the corporation. The 10% rule falls under the rules of attribution. This means that family members fall under closer scrutiny and in some situations, the individual shares of family members can be attributed to one member of the family for Subpart F. For example, a family owned corporation with say twelve members who all own a proportionate share, around 8% each, structurally avoid the 10% rule. No one owns the statutory 10% for the rule to come into play? You would be wrong to make this assumption: this is exactly where attribution will come into play and derail your plans. Meticulous care should be taken - allow a professional to assess the situation. Can These CFC Rules Be Circumvented? It is possible to set up a business to navigate around these CFC rules, but this might be a bit more difficult than it sounds, i.e. it will be risky. It can be done if you register a foreign corporation with assets under $10,000,000 in locations like the British Virgin Islands, Hong Kong or the like. However, it is imperative that you are the majority shareholder of the business. Obviously it will not be precautions at all to start up a foreign corporation and to invest substantial money in doing so with the objective to allow some third party with no real stake in the outcome to control it. It is common cause that corporation such as these remain in U.S. ownership up to a scale of between 75 and 90% and to allow foreign ownership for the balance as might be prescribed by local law. Check the video version Click for more Info

In this podcast, Elizabeth Nelson (Partner, PwC International Tax Services), Marty Hunter (Partner, PwC International Tax Services), Nita Asher (Principle, PwC International Tax Services), and Aaron Junge (Partner, PwC International Tax Services) discuss the Final and Proposed Regulations under Section 951A, highlight the effective dates of provisions, and illustrate the rules with examples. You can watch the original webcast as a replay and download the slides here. Contacts: Elizabeth A Nelson, Martin P. Hunter, Aaron H Junge, Nita Asher

In this episode of Checkpoint Presents: World of Tax, host Chris Migliaccio talks with Priya White, International Tax Manager at RSM US LLP, about the challenges in advising clients on GILTI and FDII. They cover the importance of modeling to provide client guidance, and why that’s such a big shift from the Subpart F rules.

A review of the week's major US international tax-related news. In this edition: IRS issues package of Subpart F regulations – US to share summaries of unilateral APAs with foreign governments, following OECD BEPS recommendations.

A review of the week's major US international tax-related news. In this edition: IRS final and temporary regulations under Section 871(m) issued on dividend equivalents – IRS issued final Section 368 “F” reorganization regulations -- House Ways and Means Committee approves bills to make permanent Subpart F active financing exception and CFC-to-CFC look-through rule.

IRS releases final and temporary Subpart F regulations -- Congress returns 8 September to various pending deadlines – Final OECD BEPS deliverables slated for release this fall.

A review of the week's major US international tax-related news. In this edition: US Congressional tax leaders express concern over Treasury plans for CbC reporting regulations – IRS CCA addresses “relation back” doctrine in Section 905(c) -- IRS FFA concludes portions of intercompany referral fee income generated by foreign subs improperly characterized as Subpart F income – IRS releases more international tax "practice units".

November elections leave status quo unchanged for “fiscal cliff” talks - Treasury issues second Model FATCA Intergovernmental Agreement -- FATCA negotiations moving forward -- REIT’s Subpart F and PFIC inclusions qualify under 95% income test -- IRS releases 2012 - 2013 Business Plan

US deficit, debt, and possibility of tax reform dominate debate in Washington -- Final regulations released on treatment under Subpart F and Section 367 of leasing aircraft, vessels in foreign commerce -- New 3% withholding requirement on payments from government entities to contractors delayed -- Fifth Circuit affirms Tax Court in Container Corporation-- Senate Foreign Relations Committee to hold treaty hearing 7 June -- OECD Draft addresses term "beneficial owner"