国际税务报告和规划

主要联系人: 玛丽维. 级会计师

Transactional analysis and support services including due diligence. 

税基侵蚀及防止滥用税

BEAT is an additional 税 on certain corporations that make specific types of payments to foreign related parties. The determination as to whether a corporation has made a payment that would be subject to such 税 is made by looking at a company’s base erosion percentage and gross receipts. If a 税payer falls within the requirement to pay BEAT, 然后是一个复杂的计算, 如该处所示, 是每年完成公司的纳税申报表吗. 

There are certain industries that might be more impacted by BEAT than others. Importers and those in the energy sector seem to be uniquely susceptible to BEAT, and should be cautious when making payments to their foreign related entities without carefully considering the 税 impact. If you are concerned about BEAT and want to know how Schneider Downs can help, reach out to the Schneider Downs international 税 team. 这些税务专业人员可以: 

• Aid in making the determination of whether BEAT applies to you, 
• Engage in 税 planningto model the best options for your unique business need, and 
• Ensure compliance with all relevant reporting requirements as issued by the Service. 

第F部分，遣返 

Prior to the passage of the Tax Cuts and Jobs Act (TCJA) in 2017, U.S. 外国企业的所有者可以推迟美国的税收.S. 对在美国境外获得的某些收入征税.S. until such income is repatriated to the United States (via payment of a dividend from the foreign entity to the U.S. 所有者). 当国会通过TCJA时，它允许美国.S. 股东获得新福利, 但也增加了一些新的负担, all aimed to incentivize those doing business abroad to bring profits and investmentsback to the United States. 

根据TCJA，美国.S.corporate shareholders that repatriate income via dividend are now afforded a deduction in the amount of the dividend, 有效允许U.S. shareholders to bring profits held offshore back to the United States 税-free.另外, 税payers that are leaving profits abroad in their foreign companies, 现在受到更严格的F部分规则的约束, 以及对GILTI征收新税, 或者全球无形的低税收入. The rules for calculation of subpart F income and GILTI, 分别, 是否既复杂又耗时. It takes significant modeling on the planning side and detailed analysis on the compliance side to determine the best course of action for a 税payer. Schneider Downs’ talented Global Tax team has experience in both of these areas, and is ready to help you determine your individual needs. 

关于施耐德唐斯税务顾问 

With one of the largest regional 税 practices in the country, Schneider Downs Tax Advisors’ personal focus on clients and in-depth understanding of current issues ensures that clients are complying with 税 filing requirements and maximizing 税 benefits. Our industry knowledge and focus ensures delivery of technical 税 strategies which can be implemented as practical business initiatives. 欲知详情，请浏览 4p6e3p1f.mxappzcg.com/tax-services.