Why a Section 962 Statement is Necessary
On July 10, 2020 I will present a live Section 962 webcast that goes into excruciatingly painful detail about preparing a Section 962 tax return....
On July 10, 2020 I will present a live Section 962 webcast that goes into excruciatingly painful detail about preparing a Section 962 tax return....
Introduction All of the profits generated by a minimultinational enterprise will be exposed in real time to the U.S. tax system. Chapter 2 explains why....
American minimultinationals are small (for various definitions of "small") business enterprises subjected to the U.S. tax system. There are many ways that a minimultinational becomes...
What's an American Minimultinational? What do I mean by American minimultinational? Multinational A multinational business operates in multiple countries, exposed to multiple tax-hungry governments. Apple....
The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces...