It was my pleasure to serve as editor of this year’s AICPA Tax Adviser August Tax Clinic, a special section our firm has been honored to oversee and contribute to for decades under my colleague Tony Bakale.With the passing of this torch, I was excited to be entrusted with delivering...
Read MoreTAG Alliances®, a leading multidisciplinary alliance of independent professional services firms, has appointed Ray Polantz, tax partner at Cohen & Company, as its newest advisory board member. Ray will join the TAG Alliances Advisory Board as a member of its Global Strategy Committee...
Read MoreU.S. exporters often wonder whether organizing as a C Corporation is more tax efficient than organizing as a pass-through entity, such as an S Corporation or partnership. To make this determination, U.S. exporters need to consider their ability to benefit from certain export incentives, such as...
Read MorePass-through forms of business such as S Corporations and partnerships offer certain domestic tax benefits — namely, the avoidance of double taxation and the ability to claim the 20% deduction under IRC Code Section 199A. However, the global intangible low-taxed income (GILTI) provisions of...
Read MoreToday’s economic and regulatory environment is like no other. However, as businesses face significant challenges, there are also areas of opportunity — if you know where to look. As editor of the AICPA’s Tax Adviser August Tax Clinic, a special section in the professional...
Read MoreOn June 14, 2019, the U.S. Treasury and the IRS released proposed regulations related to global intangible low-taxed income (GILTI), one of the key international provisions provided in the Tax Cuts and Jobs Act (TCJA) of 2017. The proposed regulations provide a GILTI high-tax exception...
Read MoreThe consequences of doing business in a country with which the U.S. has a tax treaty can be much different than those encountered when dealing with a non-treaty country. It’s important to understand the basic differences of each. Treaty CountriesThe United States has a number of...
Read MoreCan my private company benefit from a corporate tax inversion? I’ve been asked this question more frequently over the last few years as corporate tax inversions have gained momentum in the media and attention from politicians. The answer is, while you may be able to undergo a conversion, it...
Read MoreAmerica is the land of opportunity. However, opportunity can mean additional tax considerations, especially for foreign individuals setting up a business on U.S. soil. It is imperative to structure the business appropriately from the beginning so as not to trigger any unintended U.S. tax...
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