
INSIGHTS FROM OUR NATIONAL TAX OFFICE	MARCH 1, 2016

In Case You Missed It: International Tax Considerations

The information below provides a short review of various international tax information items Eide Bailly recently published. To read more click the "Learn more" link shown after each summary.

Considerations for Entrepreneurs Thinking Globally
Many entrepreneurs begin their business with a focus on becoming successful in their current markets and eventually expanding across state lines. As time goes on, they may test their business concept across international borders. Many U.S. companies often head first to Canada and then move on to Europe as a springboard to a global business. From a U.S. tax perspective, these companies soon learn that the profits can either be taxed immediately in the U.S., or taxed when repatriated, depending on the structure they choose. Learn more.

Understanding the Benefits of an IC-DISC: Is it Right for You?
Recently, more companies in the manufacturing industry are becoming involved in foreign transactions, including exporting. However, many are not aware that they can improve their cash flow and reduce their U.S. tax liability through the use of the IC-DISC export tax incentive. An Interest-Charge Domestic International Sales Corporation, more commonly known as an IC-DISC, is a federal tax export incentive entity structuring available for U.S. companies that export goods and services to foreign countries. Learn more.

Canada Non-Resident Employer Certification

The Canada Revenue Agency (CRA) released its Non-Resident Employer Certification program on January 12, 2016. Canada Regulation 102 requires employers, whether a resident of Canada or not, to withhold and remit withholding tax on any remuneration paid to non-resident employees who provide services in Canada, unless a waiver of withholding tax has been issued. Learn more.

United Kingdom Supreme Court rules on treatment of U.S. LLC under the U.S.-U.K. Tax Treaty

In a decision announced on July 1, 2015, the U.K. Supreme Court held that in a case where a U.K. resident is a member of a Delaware U.S. LLC and is treated as automatically becoming entitled to their share of the LLC trade or business profits under Delaware LLC Act and the LLC agreement, HM Revenue & Customs should respect such flow-through treatment with the result that the profits recognized by the U.K. individual taxpayer are eligible for double tax relief under the U.S.-U.K. Tax Treaty. Learn more.

Foreign Information Returns: The Cost of Not Filing

Do you file an international informational return? Or, more to the point, should you be filing an international information return? Generally, the statute of limitations for the IRS to assess all income taxes is within three years after a taxpayer's original income tax return is filed, but for international taxpayers, the statute of limitations is extended indefinitely when certain international information returns are not filed. Learn more.

Eide Bailly's National Tax Office serves as a resource for clients to help analyze complex tax issues related to business decisions. Our professionals are committed to helping clients stay informed about tax news, developments and trends through various specialty areas, including cost segregation studies, wealth transfer, state and local taxation, international tax, IRS controversy and procedures, R&D tax incentives, tax-exempt organizations, tax legislation, accounting methods and pass-through entities.

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This article is intended to provide readers with guidance in tax matters. The article does not constitute, and should not be treated as professional advice regarding the use of any particular tax technique. Every effort has been made to assure the accuracy of the information. Eide Bailly LLP and the author do not assume responsibility for any individual's reliance upon the information provided in the article. Readers should independently verify all information before applying it to a particular fact situation, and should independently determine the impact of any particular tax planning technique before recommending the technique to a client or implementing it on the client's behalf. To request reprints of this publication, send a written request to RequestReprints@eidebailly.com. © 2016 Eide Bailly LLP.