PRIMARY CONTACTS: Mary D. Richter CPA

Transactional analysis and support services including due diligence.

税基侵蚀及防止滥用税

BEAT is an additional tax 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 tax is made by looking at a company’s base erosion percentage and gross receipts. If a taxpayer 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 tax impact. If you are concerned about BEAT and want to know how Schneider Downs can help, reach out to the Schneider Downs international tax team. 这些税务专业人员可以:

• Aid in making the determination of whether BEAT applies to you,
• Engage in tax planning to 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. owner). 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 investments back to the United States. Per the TCJA,U.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 tax-free. Additionally, taxpayers 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, respectively, 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 taxpayer. 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 tax 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 tax filing requirements and maximizing tax benefits. Our industry knowledge and focus ensures delivery of technical tax strategies which can be implemented as practical business initiatives. Learn more at Tax Services.