The Complexity of International Tax Issues

The U.S. tax rules governing U.S.-owned foreign businesses are complex, particularly when you are reviewing a contemplated transaction where the acquirer or target is foreign, has foreign shareholders, or the target owns foreign subsidiaries or branches.

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• Inbound Investment: Tax Consequences for Non-U.S. Investors Acquiring Stock or Debt Instruments of U.S. Issuers
  Examine the principal U.S. federal income tax consequences that non-U.S. investors in stock and securities of U.S. issuers should consider before making an investment in a U.S. corporation. They typically face special tax issues related to withholding, taxation of capital gains, taxation of income “effectively connected” with a U.S. trade or business, and the Foreign Investment in Real Property Tax Act (FIRPTA) regime.
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  • Employee Benefits. Infrastructure Investment and Jobs Act enacted, including five-year extension of American Rescue Plan Act’s pension funding interest rate relief for single-employer DB plans. The Act also makes changes to the employee retention tax credit. L. No. 117-58, § 80602.
  • Employee Benefits. IRS issues the 2021 Required Amendments List which establishes the end of the remedial amendment period and the plan amendment deadline for changes in qualification requirements to individually designed section 401(a) qualified plans and section 403(b) requirements, respectively. R.S. Notice 2021-64
  • Business Entities. IRS provides guidance for partnerships and consolidated groups regarding amounts excluded from gross income and deductions relating to the Paycheck Protection Program and certain other COVID-19 relief programs. Proc. 2021-49.
  • Compensation/Employee Benefits/Payroll. IRS provides that taxpayers may treat amounts that are excluded from gross income (tax-exempt income) in connection with the forgiveness of Paycheck Protection Program (PPP) Loans as received or accrued: (1) as eligible expenses are paid or incurred, (2) when an application for PPP Loan forgiveness is filed, or (3) when PPP Loan forgiveness is granted. To the extent tax-exempt income resulting from the forgiveness of a PPP Loan is treated as gross receipts under a particular Federal tax provision, this guidance applies for purposes of determining the timing and, to the extent relevant, reporting of such gross receipts. Proc. 2021-48.
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