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International Tidbit


Introduction to International Tidbits

Starting with our January issue, this monthly feature called "International Tidbits" will be authored by UHY Advisors’ Tax Professionals, whose focus includes international tax planning and compliance.

This first tidbit focuses on the worldwide network of more than 200 offices in over 75 countries known collectively as UHY. Click here to visit their website. Each country has published a guide on doing business, including the basic information on the taxes in the country and how they impact foreign investors.  These guides are available online as pdf documents that can also be downloaded here and saved to your computer.  In addition, each member firm has a profile on the site with a list of contact information and link to its own website detailing the services it offers.
 
UHY International publishes "International Business" online and focuses on developments around the globe of interest to businesses with cross-border investments.  Recent features have included an update on African trade blocs, investment in emerging markets, combatting fraud in an economic downturn, transfer pricing, and tax treaties.  Click here to access this publication online.
 
The Tax Special Interest Group of UHY International publishes the Global Transfer Pricing Guide which summarizes the rules for each country, including permissible methodologies for determining arm's length pricing, key differences from OECD transfer pricing guidelines, and the documentation that taxpayers are required to maintain.
 
UHY Advisors takes an active role in UHY at the international level, including providing the Chair for the Tax Special Interest Group and encouraging the sharing of tax information and updates throughout the worldwide network.

 
Click the links below to view past articles:

Jan24 1/24/2012 3:17:00 PM by Meril Markley and Mesa Hodson

The Hiring Incentives to Restore Employment (“HIRE”) Act, signed into law in 2010, included modified provisions of the previously proposed Foreign Account Tax Compliance Act of 2009 (“FATCA”). These provisions involve two broad categories of tax compliance: reporting by foreign financial institutions on accounts held by U.S. persons, and reporting by U.S. individuals on specified foreign financial assets. It is the latter category that led to the new Form 8938 Statement of Specified Foreign Financial Assets, to be filed in 2012 as part of an individual’s 2011 federal income tax return.

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Dec14 12/14/2011 12:23:00 PM by Meril Markley

A little over a year ago, Google made headlines with news that its offshore tax rate was a mere 2.4% thanks to a complex structure involving jurisdictions such as Bermuda, Ireland, and the Netherlands. Can today’s technology start-ups hope for similar benefits from a global strategy by transferring non-U.S. rights for their valuable intellectual property to a foreign corporation? The answer, as with most things involving U.S. income tax, is an unequivocal “yes, but,” plus the admonition that planning for various alternatives will still be key.

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Nov15 11/15/2011 3:27:00 PM by Meril Markley

UHY Advisors TX, LLC is not the only one with a milestone birthday in 2011. Although not yet celebrating 40 years, such as UHY in Texas, UHY International as a network of Member Firms marks its 25th anniversary this year.

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Oct18 10/18/2011 10:35:00 AM by Meril Markley

This month we look at the importance of checking for special terms covering energy-related activities in double taxation treaties (“DTT”) between the U.S. and other countries so U.S. companies can gauge potential PE exposure before they submit a bid or sign a contract.

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Sep19 9/19/2011 11:42:00 AM by Meril Markley

This month and next we focus on the risks of having a Permanent Establishment (“PE”) in a foreign country and accidentally becoming subject to the full panoply of taxes imposed there. Part I, this month, focuses on the general concept of a taxable Permanent Establishment (“PE”) as it is used in double taxation treaties between the U.S. and foreign countries, but does not rely upon any specific treaty.

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