Straight Talk on Inversions

by Bill Henson on October 10, 2014

The corporate structuring transaction known as an “inversion” has been front and center recently regarding U.S. corporate tax policy. Corporate inversions typically involve the acquisition of a U.S. corporation by a foreign corporation, during which the U.S. corporation’s shareholders acquire a majority interest in the “acquiring” foreign corporation. Read more at

If you have any further questions, please contact Bill Henson at 312-602-3635 or


The foreign bank and financial account reporting rules require anyone with signature authority over a reportable foreign bank account to complete and file Form 114. Many times, an entity that has a reportable foreign bank account will have an employee that has signature authority over the foreign account. Such employees are required to submit their own foreign bank account report, Form 114, to report the signature authority, if such authority existed at any time during the tax year.

A client recently raised a question regarding the reporting requirements applicable to an employee whose signature authority is terminated during the middle of a tax year, especially if the employee has left the employer. For example, if the employee is terminated on May 31, 2014, would the employee be required to report the highest balance during the calendar year 2014 or only the highest balance of the account through the date of termination of employment?

In order to get clarification on this issue, we called the IRS Bank Secrecy Act Helpline in Detroit (866-270-0733). The agent confirmed that the employee is only required to report the highest balance during the period of time that he or she had the signature authority. In the example above, the employee would only be required to report the highest balance through May 31, 2014.

If you have any additional questions, please contact Matt Brady at or Carla Smaston at



Importance of Post‐Merger Integration

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“Going global” is one of the key focuses for many companies nowadays. Accordingly, cross-border mergers and acquisitions (M&A) has been on the rise, and the trend is expected to continue. Considering post‐merger integration (PMI) plans during the M&A process is as important as considering purchase pricing and financial risks. PMI encompasses everything from financial reporting […]

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IRS Announces Revisions to Its Offshore Voluntary Disclosure Program

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Oops! The IRS Did It Again! OVDP-2014 Announced The IRS does not seem to be able to leave well enough alone for more than a year or two at a time.  While the last change, in 2012, is only a couple of years old, the IRS announced new revisions that took effect on July 1, […]

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2014 Double Eagle Awards Dinner

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Each year the U.S.-Mexico Chamber of Commerce hosts a Double Eagle Awards Dinner. The purpose of this dinner is to honor a group of private sector companies and a public sector individual with its Double Eagle Awards. The award criteria are based on a company’s commitment and initiatives to build a stronger relationship between the […]

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Pushing Down Expenses: Are you Minimizing Your Worldwide Effective Tax Rate?

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There are many strategies that internationally active U.S. companies can exercise to minimize their worldwide effective tax rates. One such strategy is to be diligent about charging out expenses to your foreign branches and foreign flow-through entities. For illustration purposes, think of the very popular business structure of a U.S. company that has a “check […]

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Tax Benefits for Exporters

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The U.S. tax code contains a number of incentives for desirable activities that U.S. taxpayers can engage in.  Some of the incentives can come and go at the whim of Congress, like the research & development credit, but the one incentive that has remained relatively unchanged since 1971 is a benefit for U.S. exporters.  That […]

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Are There Hidden Costs Within Your Global Structure?

January 24, 2014

There are a variety of concerns when considering an international structure, from regulatory requirements and income tax efficiency to ease of moving capital or even employee benefit impacts. However, one that rarely seems to enter into the decision-making process is statutory audit and financial statement requirements. A previous blog post on September 30, 2013, discussed […]

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What do Apple and Amazon have in common?

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a. They’re both headquartered on the West coast. b. They both started in garages. c. Their stocks have both seen incredible growth over the years. d. They’ve both been scrutinized by the government for their international tax strategies. Although all four statements are true, it’s “D” that we’d like to direct your attention toward today. […]

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FATCA Withholding Begins in July 2014 – What does that mean and what should be done to prepare?

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One of the hottest topics of discussion among international tax practitioners and multinational business as we enter 2014 is the continued implementation of the Foreign Account Tax Compliance Act, or FATCA.  We have already seen some of the aspects of FATCA with the introduction of Form 8938 for individuals, the issuance of new draft W-8’s […]

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