The U.S. Department of the Treasury recently announced that the United States notified Hungary of its termination of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, in force since 1979.

In a Private Letter Ruling (PLR), the IRS granted a foreign eligible entity a 120-day extension to file Form 8832, where U.S. businesses which own foreign entities can effectively structure their foreign entities for U.S. tax purposes.

In response to logistical hardships imposed by the COVID-19 pandemic, the IRS released Notice 2022-36 in its Internal Revenue Bulletin providing relief of penalties relating to the failure to file certain international informational returns for the 2019 and 2020 tax years.

The Inflation Reduction Act will give the IRS billions to go into enforcement, operations, systems modernization, and customer service. The increased funding for IRS enforcement will significantly increase the IRS’s scrutiny of transfer pricing compliance.

In this webinar, Sean King discusses common pitfalls for M&A transactions and how to properly plan to alleviate the complexities of doing business across borders.

Preparing international compliance forms which end up part of a U.S. federal tax return involves avoiding a multitude of potential errors. Knowing the most common tax-filing oversights is critical to prevent mistakes and the serious headache that results in IRS scrutiny that can lead to an assessment of interest and penalties.

When helping clients get current with filing delinquent returns of prior years, we are always asked the question “How far back do we have to go?”

Jason Rauhe  talks about how we serve international clients, the importance of compliance, and hot topics in the international tax world.

In a surprising development, Senate Majority Leader Chuck Schumer, Senator Joe Manchin and President Joe Biden on 27 July announced a deal on a $740 billion reconciliation bill.

This blog discusses the revised time estimates for enacting a revamp of international tax rules.

Jason Rauhe, CPA is a Principal in the firm’s Global Business Services practice and is responsible for assisting clients and adding depth in all areas of the firm’s international tax consulting services including transfer pricing, and the firm’s compliance expertise.

Rauhe previously served as Director of International Tax at a Top 100 CPA Firm, where he was responsible for the firm’s international tax division and major industry alliance networks.

Recent Resources

  • blog
    Global Business Services
    September 23, 2022

    Form 8832: PLR Granting Extension and Late Election Relief

    by Jason Rauhe

    In a Private Letter Ruling (PLR), the IRS granted a foreign eligible entity a 120-day extension to file Form 8832,...

  • blog
    Global Business Services
    September 9, 2022

    IRS Notice 2022-36

    by Jason Rauhe

    In response to logistical hardships imposed by the COVID-19 pandemic, the IRS released Notice 2022-36 in its Internal Revenue Bulletin...

  • blog
    Global Business Services
    September 2, 2022

    The New IRS Army: Transfer Pricing Implications

    by Sean King

    The Inflation Reduction Act will give the IRS billions to go into enforcement, operations, systems modernization, and customer service. The...

  • blog
    Global Business Services
    April 8, 2022

    Global Business Blog Series

    by Sean King & Jason Rauhe

    International business is fraught with opportunity but not without risk of the unknown. In his weekly blog series, Sean King...