Entries by Manager

IRS Classification of Foreign Entities: “Per Se” Foreign Corporations

For the U.S. tax compliance purposes, it is very important to properly classify foreign business entities, because there are special IRS requirements associated with ownership of foreign business entities. For instance, a list of various tax forms is tied to particular classification (for example, certain U.S. taxpayers are required to file Form 5471 with respect […]

Form 941 Penalties

In a previous article, we covered some of the basics of Form 941. In this article, we will explore some of the major penalties that may apply for failure to comply with the requirements of Form 941. These penalties may be severe and, in certain circumstances, may even lead to criminal charges. Failure to File […]

Treasury and the IRS Issue Proposed Regulations for FATCA Implementation

On February 8, 2012, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations for the next major phase of implementing the Foreign Account Tax Compliance Act (FATCA). FATCA and FFI Reporting under Proposed Regulations FATCA was enacted by the U.S. Congress in 2010 as part the Hiring Incentives to Restore Employment (HIRE) […]

CPT (Carriage Paid To)

The purpose of this article is provide a general background to one of the most important terms in international contract drafting, Incoterms 2010 CPT. General Provisions of CPT CPT (Carriage Paid To) means that the seller delivers the goods to the carrier of another person nominated by the seller at an agreed place and that […]