In a welcome announcement, certain transitional rules to implement aspects of the Foreign Account Tax Compliance Act (FATCA) have been extended. Issued on September 18, 2015, this notice announces that the Department of Treasury and the Internal Revenue Service intend to amend the regulations to extend the period of time the transitional rules will apply. Until this amendment officially occurs, taxpayers may rely on the current provisions.

So what, exactly, was extended? Here are a few of the key, widely applicable, extensions:

  1. Gross proceeds withholding to payments occurring after December 31, 2018.
  2. Time for sponsored entities to get their own registration completed to December 31, 2016.
  3. Deadlines for compliance in countries still developing procedures to implement intergovernmental agreements to September 30, 2016.

Our international tax team can assist in compliance with FATCA requirements. Please reach out to us if you have general questions about FATCA or if you believe specific items in this this notice may be applicable to you.


It’s Not You; It’s the Audit Rotation Rules

by Keith Piwko on September 17, 2015

Although some U.S. companies have a history of changing audit firms, many have developed long-term relationships with their auditors. After all, we’re known for adding life to any party—what’s not to love?

These relationships may be cut short, however, due to the audit rotation rules governing a company’s foreign parent.

Most countries have developed their own audit standards. While there are similarities among countries in many key areas, one area that’s maddeningly inconsistent pertains to audit firm rotation requirements. While public companies in the United States are required to rotate audit partners periodically, nothing has been addressed regarding audit firms. (There are currently no rotation requirements for nonpublic U.S. companies). This is not the case for many foreign countries, however.

While most foreign auditing standards aren’t clear as to whether subsidiaries outside the home country must rotate audit firms to match their parents’ rotation schedules, foreign subsidiaries and their audit firms are more likely to be impacted when they make up a much larger portion of the consolidated group. And both audit firms and audit partners may be affected.

Don’t be caught off guard. If audit rotation could be an issue for your subsidiary, address it with your parent company’s finance team. This will allow you to better understand the group auditor’s viewpoint and, if necessary, plan ahead to reduce any unforeseen disruptions. After all, communication is the cornerstone of any successful relationship.


Reminder- Do You Have an IMMEX Level “A” Certification? It’s Time to Renew.

August 31, 2015

Back in October 2013, the Mexican government published a few revisions to the IMMEX decree, including requiring participating companies to obtain a certification in order to qualify for certain tax and customs benefits. If your company received a Level “A” certification during 2014, it’s only valid from January 1, 2015, through December 31, 2015. You’ll […]

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Intellectual Property May Soon Be Deductible

August 25, 2015

What if we told you that you could deduct 71 percent of your company’s income derived from qualifying intellectual property (IP)—that patents, inventions, formulas, processes, knowhow, computer software, and any other IP could qualify? Thanks to the Innovation Promotion Act of 2015, that could soon be the case. Charles Boustany and Richard Neal, two members […]

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Currency Instability Exposes Accounting Policy Weaknesses

August 6, 2015

Economic volatility in Greece, Russia, Venezuela, Brazil, and other major countries has decreased demand for many local currencies and increased the demand for U.S. dollars. This has resulted in a devaluation of most major currencies over the last 12 months: 8 percent for the British pound, 19 percent for the Canadian dollar, 21 percent for […]

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China Eases Restrictions on the Currency Control System

May 26, 2015

On March 30, 2015, the Chinese State Administration of Foreign Exchange (SAFE) eased its restrictions on the currency controls system. This means an increase in the flexibility of Foreign Invested Enterprise (FIE) currency management in China, with an aim to allow companies to settle their foreign exchange capital and to hedge currency risks. Briefly, the […]

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New Non-Tax International Reporting Requirements – Due May 29

May 21, 2015

In November 2014, the Bureau of Economic Analysis (BEA) updated the filing requirements related to their Benchmark Survey, the BE-10 Survey.  It is now mandatory for U.S. companies that own a foreign affiliate (had direct or indirect ownership of at least 10 percent of the voting stock) to complete the survey. This survey is done […]

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Chinese Tax Authority — Policy Reminder on Accelerated Depreciation of Fixed Assets

February 4, 2015

The Chinese Tax Authority issued a new policy on accelerated depreciation of fixed assets to promote technology innovation and economic development in China (Circular 75).  This policy expands the scope of fixed assets that are eligible for accelerated depreciation methods for corporate income tax (CIT) deduction purposes.  This new policy allows manufacturing companies to accelerate […]

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New Joint Initiative – U.S. & Canada to Share Information on Individuals Crossing the Border

November 18, 2014

The United States and Canada recently announced an initiative to track individuals crossing the border for both work and for personal reasons. The initiative will track the number of days a resident of one country works or stays in the other country during a calendar year. The foreign individual will have their days in Canada […]

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China Tax Authority – Outbound Payments Under the Spotlight

November 13, 2014

The Chinese tax authorities have enhanced their efforts to monitor intra-group outbound service payments and royalty charges. In July 2014, the highest tax authority in China, the State Administration of Taxation (SAT), released the “Notice of Anti-Avoidance Examination on Significant Outbound Payments.” In this notice, the SAT instructs the local tax bureaus to launch comprehensive […]

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