November 2019

Update on US Sales and Use Taxes – Retro-activity and VDAs

The ongoing drama around sales and use taxes continues.  Despite the fact that forty-one states, two U.S. territories, and the District of Columbia joined the amicus brief supporting South Dakota’s position before the Supreme Court and stating otherwise, the State of California is now retroactively seeking sales tax from out-of-state online merchants, going back as

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How To Handle Dual Residents: IRS Tiebreakers

Treaty nonresident positions are interesting.  Before 2023 we would have said that no tax returns may be due but informational returns are due because of IRS regulations.  Now things are uncertain.  In Aroeste v. United States, No. 22-cv-00682, Judge Karen S. Crawford, a U.S. magistrate judge, considered whether Mr. Aroeste’s status under the treaty has any

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Transfer Pricing in the USA

The IRS has made it clear that Transfer Pricing is a priority.  Check the link here – https://www.mooresrowland.tax/2019/05/captive-services-provider-campaign.html What do we mean by Transfer Pricing? Why do Governments care? Therefore it is a hot topic globally including jurisdictions in which we have many clients such as – Singapore – https://www.mooresrowland.tax/2019/11/tax-planning-in-singapore.html Indonesia – https://www.mooresrowland.tax/2019/10/transfer-pricing-in-indonesia.html Australia – https://www.mooresrowland.tax/2019/11/australia-tax-residence-and-fiscal.html Hong Kong – https://www.mooresrowland.tax/2019/07/corporate-tax-guide-hong-kong-special.html

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Tax Planning on U.S. inbound investment

Acquisitions (from the buyer’s perspective) Tax treatment of different acquisitions What are the differences in tax treatment between an acquisition of stock in a company and the acquisition of business assets and liabilities? Taxable acquisitions Stock acquisitions –All assets and liabilities of the target as they exist immediately prior to the closing are assumed in

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Switching From S to C Corporation Taxation?

We have previously discussed LLCs and S Corps –  https://www.mooresrowland.tax/2018/12/the-pros-and-cons-of-llcs.html https://www.mooresrowland.tax/2014/09/irs-partners-share-of-llc-income-is.html https://www.mooresrowland.tax/2019/08/strategies-that-partners-or-llc-members.html We also discussed converting from an LLC to an S corp –  https://www.mooresrowland.tax/2019/03/converting-llc-to-s-corp.html Now let’s talk about converting from an S to a C Corp –  Anticipating that the reduction of the corporate tax rate to 21% would result in taxpayers eager to

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Tax Planning in Singapore – Offshore Financial Center – Company Taxation

  Being based in Singapore means that it is a jurisdiction that we believe in and actively promote.  When talking to international entrepreneurs considering their options for structuring their businesses, Singapore always comes up. I also write about it frequently – https://htj.tax/?s=singapore Today I thought I would go into it more deeply. Singapore generally imposes

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CORPORATE TAX GUIDE: HONG KONG SPECIAL ADMINISTRATIVE REGION

Both  Hong Kong and Singapore offer offshore or tax-free companies. . It’s hard to say which is better for setting up an offshore entity.  It really depends on your business model. . For most people I say 2 things – 1. Hong Kong allows a local bank account for offshore companies but it takes years

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Responsible Person rules in the wake of Wayfair – You can be PERSONALLY Liable for Sales and Use Taxes

We previously wrote on this topic –  https://www.mooresrowland.tax/2019/10/navigating-post-wayfair-world.html https://www.mooresrowland.tax/2019/10/states-business-activity-tax-nexus.html If you’re new to remote selling, then I suggest you first start here –  https://www.mooresrowland.tax/2019/11/6-steps-to-starting-your-location.html Sales and use taxes are “trust fund taxes,” or taxes that the collector holds “in trust” for the state until remittance. These taxes are imposed not on the seller but on

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