International Tax Alert
On January 1, 2010, several taxpayer-favorable provisions of the Internal Revenue Code expired.
One of the most significant provisions for International Tax is IRC Section 954(c)(6), Look-Thru Rule for Related Controlled Foreign Corporations.
If the extension of the look-thru rule is not enacted before the balance sheet date, an entity should consider including in the financial report a discussion related to the impact of the lapse, as well as the impact expected if the proposal is later enacted.
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Amper's International Services Group
Amper's International Services Group is committed to providing quality tax, accounting, auditing and consulting services to private and public companies with global operations.
A Regional Firm With a Global Reach
International businesses face exciting and significant challenges. Amper’s International Services Group offers a range of specialties in order to help our clients meet those challenges.
The experience of our team members – along with our knowledge of global markets – provides our clients with a strong, comprehensive and efficient service approach.
Key to this approach is our commitment to partner-level participation in all phases of client service, ensuring continuity and efficiency in the services we provide. Our professionals stay current through continuing education and active participation in organizations that focus on international issues.
Whether you are looking into entering new markets internationally or expanding existing global operations, Amper has the depth of resources and the broad perspective you can count on.
A Wide Range of Services to Meet Your Needs
Amper’s International Services Group is committed to helping businesses identify the opportunities and implement the strategies that will help assure their success. We offer a wide range of services to meet your needs:
Audit (IFRS – Translate IFRS to GAAP and GAAP to IFRS)
Tax:
Inpats/Expats
Tax Planning
Income Tax
Estate of Non-Residents
Transfer Pricing
Recovery Work:
Financing
Management Consulting
Business Restructuring
Trusts:
Foreign Trusts with U.S. Owners
Foreign Trusts with U.S. Beneficiaries
Business Entities:
U.S. Subsidiaries of Foreign Entities
Foreign Subsidiaries of U.S. Companies
Cross-Border Transactions (TRF Pricing)
Contact: Rich Sackin , Brian Downey, Peter Bible
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