Michigan SALT Cap Workaround Details Released
Posted by Sue Tuson on December 22, 2021
Sue Tuson
Michigan’s Governor has signed a SALT Cap Workaround to avoid the $10,000 limit on individual deductions for state and local taxes at the federal level. The rules are effective for tax years beginning on and after January 1, 2021. Learn about the key details and business considerations.
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Michigan SALT Tax News Impacts Owners
Posted by Sue Tuson on September 30, 2021
Sue Tuson
In mid-summer 2021 Michigan Governor Gretchen Whitmer vetoed a bill that would have provided a workaround to the current cap on the deduction for state income taxes that business owners face on pass-through income.
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Historic Global Tax Reform on the Horizon
Posted by Sue Tuson on August 10, 2021
Sue Tuson
The G-20 international forum met in July to discuss plans to create a global minimum tax of 15%. The OECD has proposed a two pillar framework designed to address the needs of a global digital economy. Review the key aspects and potential impacts of this proposed tax reform.
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New GST/HST Filing Requirements for E-Commerce in Canada
Posted by Sue Tuson on July 12, 2021
Sue Tuson
If you’re a foreign company selling goods or services online in Canada, review these new GST/HST filing requirements for e-commerce deals, expected to become law with a retroactive date of July 1, 2021.
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International Impacts of President Biden’s Tax Proposals
Posted by Sue Tuson on June 3, 2021
Sue Tuson
On May 28, 2021, the U.S. Treasury released its Fiscal Year 2022 explanation of the various proposals included in President Biden’s “Made in America” tax plan, known as the Green Book.
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COVID-19 and the Supply Chain: How to Manage the Impacts
Posted by Sue Tuson on May 25, 2021
Sue Tuson
As multinational companies see imports rising to pre-pandemic levels, they should remain vigilant about supply chain impacts including transfer pricing.
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Cross-Border Related Party Transactions: Impact of COVID-19
Posted by Sue Tuson on March 23, 2021
Sue Tuson
Learn how to protect your business against potential transfer pricing adjustments and penalties due to the global pandemic.
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Payroll Tax Deferral IRS Guidance
Posted by Sue Tuson on August 28, 2020
Sue Tuson
Learn about the recently issued guidance as it relates to President Trump's Executive Order on employee side payroll deferral.
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Relief with International Tax Deductions
Posted by Sue Tuson on August 19, 2020
Sue Tuson
The Tax Cuts and Jobs Act (TCJA) of 2017 provided a benefit for corporations that export goods or services by creating a foreign-derived intangible income deduction (FDII), also referred to as a section 250 deduction.
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COVID-19 Relief: Executive Orders
Posted by Sue Tuson on August 12, 2020
Sue Tuson
The news over the past few weeks has been filled with stories about the failed attempts of Congressional leaders and the White House to agree upon new COVID-19 relief legislation.
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New Nexus Standards for Remote Sellers
Posted by Sue Tuson on July 23, 2020
Sue Tuson
Most equipment manufacturers in manufacturing-friendly states like Michigan take it for granted that equipment used in manufacturing is exempt from sales tax in other states. Much to their unhappy surprise, it is not the case in all states!
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State Tax Questions as We Move Back to Business
Posted by Sue Tuson on May 12, 2020
Sue Tuson
As businesses start to reopen, we look to the future imagining what the new “normal” will look like. During the crisis, most states have been taxpayer friendly, extending filing deadlines and payment due dates.
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International Investment Filing Date: BE-10
Posted by Sue Tuson on March 27, 2020
Sue Tuson
Every five years, the U.S. Department of Commerce Bureau of Economic Analysis (BEA) requires that people with certain investments abroad file a survey. The mandatory survey is based on investments held at the end of the 2019 fiscal year.
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Why Choose Michigan for Your Foreign Subsidiary?
Posted by Sue Tuson on March 10, 2020
Sue Tuson
When making the strategic decision to expand a business into the U.S. it’s important to carefully plan for the various challenges inherent in the process. Strategic issues such as supply chain development, vendor management, and production optimization.
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Impact of Revenue Recognition Changes for GAAP/IFRS on Tax Returns
Posted by Sue Tuson on February 17, 2020
Sue Tuson
The new revenue recognition standards under Generally Accepted Accounting Principles (GAAP) became effective for private companies for annual reporting periods beginning after December 15, 2018.
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Global Expansion: Investing in a Subsidiary
Posted by Sue Tuson on January 17, 2020
Sue Tuson
Businesses are consistently evaluating how to stay competitive. Global expansion may be the answer for a business to reach new markets, meet current customer needs, reduce costs, or find talent.
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Considerations When Expanding Outside the U.S.
Posted by Sue Tuson on November 12, 2019
Sue Tuson
Establishing a subsidiary outside the U.S. presents tremendous opportunities and benefits. Succeeding in global markets requires significant time, energy and resources on the part of business owners and decision-makers.
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Wayfair: A Year Later
Posted by Sue Tuson on October 1, 2019
Sue Tuson
It’s been over a year since the US Supreme Court’s ruling in South Dakota v Wayfair[1]overturned the long-standing physical presence standard for imposing a sales and use tax collection responsibility. Wayfair overturned the requirement for a physical presence in a state that was established in the 1992 case, Quill Corporation v North Dakota[2].
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US Tax Treaty Updates Japan and Spain
Posted by Sue Tuson on September 9, 2019
Sue Tuson
Long-awaited treaty protocols, signed in 2013, were finally ratified in July 2019. The protocol with Japan entered into force on August 30, 2019, provides amendments to the 2003 tax treaty. The protocol with Spain is due to enter into force on November 27, 2019, and provides for the amendments to the 1990 treaty.
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US Reporting of Foreign Subsidiaries
Posted by Sue Tuson and Teresa Gordon on August 28, 2019
Sue Tuson
The IRS continues to increase scrutiny of the reporting requirements applicable to foreign persons and U.S. companies with foreign transactions. It is important to fully understand these U.S. obligations because failure to report...
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Thinking of Expanding your Business Overseas?
Posted by Sue Tuson on July 18, 2019
Sue Tuson
Thinking of expanding your business overseas? The first question is usually, “What’s the best way to start? Should I set up an office immediately or use an independent contractor familiar with the country?”
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Benefit for Exports: Foreign Derived Intangible Income Deduction
Posted by Sue Tuson on July 2, 2019
Sue Tuson
The 2017 Tax Cuts and Jobs Act (TCJA) has made C-Corporation status much more attractive to business owners, and the 21% flat tax rate has caused many to consider whether converting to a C-Corporation may be worth the switch.
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Mandatory Government Survey—Survey of US Persons Service and IP Transactions with Foreign Persons
Posted by Sue Tuson on May 15, 2018
Sue Tuson
The US Department of Commerce Bureau of Economic Analysis (BEA) has issued a mandatory survey of select services and intellectual property transactions with foreign persons.
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Tax Reform Benefits for Corporate Exporters
Posted by Sue Tuson on April 24, 2018
Sue Tuson
The Tax Cuts and Jobs Act created a deduction for Foreign-Derived Intangible Income (FDII). The name of this deduction is misleading, it is actually a deduction against qualifying export income after a routine rate of return.
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Basics of an IRS Audit
Posted by Sue Tuson on February 2, 2018
Sue Tuson
When a taxpayer is notified by the IRS for a tax return audit, the first reaction may be panic or fear. Understanding the audit process …
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Payments of US Source Income to Foreign Parties: Withholding & Reporting
Posted by Sue Tuson on January 31, 2018
Sue Tuson
This time of year businesses are busy preparing year-end information returns, including W-2s and 1099s. Often overlooked are the rules regarding withholding and information reporting …
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Record Keeping for Information Reporting
Posted by Sue Tuson on September 8, 2017
Sue Tuson
The IRS and state governments continue to increase requirements and penalties for information reporting. With these increases, using best practices when keeping records is …
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Cross-Border Taxation Update
Posted by Sue Tuson on May 25, 2017
Sue Tuson
The IRS announced 13 audit campaigns last March. Included in the campaign is an effort to increase voluntary compliance for Form 1120-F Non-Filers. Form …
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Year-End Reporting Requirements
Posted by Sue Tuson on October 25, 2016
Sue Tuson
As we approach the end of 2016, following are items you should consider with regard to year-end reporting for your business. Forms 1099 Businesses often …
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Michigan Sales & Use Tax Adopts Affiliate Nexus and Click-Through Nexus Laws
Posted by Sue Tuson on June 21, 2016
Sue Tuson
In an effort to increase sales and use tax revenues, Michigan has adopted Affiliate Nexus and Click-Through Nexus laws. The Michigan Department of Treasury recently …
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Have Accrued Wages or Bonuses? Beware of IRC §409A
Posted by Sue Tuson and Nina Wang on June 14, 2016
Sue Tuson
Do you have wages or bonuses that were earned by employees or independent contractors but have not been paid to them after year-end? If you …
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Report of Foreign Bank and Financial Accounts (FBAR)
Posted by Sue Tuson on May 31, 2016
Sue Tuson
If you have a financial interest in, or signature authority over, a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or …
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India Withholding Taxes
Posted by Sue Tuson on April 26, 2016
Sue Tuson
US companies doing business with Indian entities may be subject to withholding taxes at the time the customer makes the payment. Generally, withholding occurs on …
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Making Payments to a Foreign Person
Posted by Sue Tuson and Nina Wang on December 29, 2015
Sue Tuson
Every United States person that makes payments of fixed, determinable, annual, or periodical (“FDAP”) income (such as dividends, interest, royalties, and certain payments for personal …
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831(b) – Captive Insurance Company
Posted by Sue Tuson on August 13, 2014
Sue Tuson
Considering a Captive Insurance Company Many companies may encounter a situation where the premium to cover an insurable risk in their business comes with a …
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Repair Regulations
Posted by Sue Tuson on September 12, 2013
Sue Tuson
The IRS has attempted to clarify what was once a very ‘grey area’ for taxpayers by issuing T.D. 9564. These temporary regulations have given businesses …
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Brazil Issues Legal Guidance on Safe Harbor Rules
Posted by Sue Tuson on February 19, 2013
Sue Tuson
On January 18, 2013, the Brazilian tax authority issued Legal Guidance 1.321/2013 providing transfer pricing safe harbor rules applicable to transactions involving exporting of goods …
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US Subsidiaries of Foreign Owned Businesses May Qualify for the Research & Experimentation Tax Credit
Posted by Sue Tuson on March 7, 2012
Sue Tuson
The Credit for Increasing Research Activities, also known as the Research and Development (R&D) tax credit or the Research and Experimentation (R&E) tax credit, is …
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IRS Steps Up Enforcement Related to Payments to Foreign Parties
Posted by Sue Tuson on March 2, 2012
Sue Tuson
The IRS has stepped up efforts to increase taxpayer compliance with foreign information reporting. It is now common practice for IRS auditors to ask for …
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New Reporting Requirement for Ownership of Specified Foreign Financial Assets
Posted by Sue Tuson on February 15, 2012
Sue Tuson
For years beginning after March 18, 2010 (for most individuals this will be calendar year-end 2011), certain individuals must file new Form 8938, Statement of …
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