American investors that desire to easily add foreign companies onto their investment portfolio should become familiar with American depositary shares (ADSs) and American depositary receipts (ADRs).
If you are a non-US shareholder of a corporation, then you have likely faced some difficulties when it comes to tax considerations. Maybe you have also noticed that it can be difficult to discern the difference between a US shareholder and a non-US shareholder. This article will provide general information
This article will provide a general understanding of how to make a Qualified Electing Fund (QEF) election as well as some of the effects that these elections can have.
Companies should carefully consider whether or not they are classified as a Passive Foreign Investment Company (PFIC). This is because being a PFIC can have unfavorable consequences to a company and its shareholders.
A US holder with shares in a Passive Foreign Investment Company (PFIC) will likely realize that there can be negative tax implications for being a holder of a PFIC. Luckily, these consequences can be avoided in two ways: by either making a Qualified Electing Fund (QEF) election or by making
This short article addresses some of the key points and timelines a business should know when considering and/or applying for the Paycheck Protection Program under the CARES Act.
Taxation of stocks can be a complex tax item for a company and its stockholders. This article addresses some of the key points and considerations on taxation of stock dividends, taxation of stock sales, and taxation of stock redemptions. Payment in Kind Dividends’ taxation is based on whether they are
A multinational company with a presence in countries outside of the United States, while doing transactions amongst its subsidiaries and affiliates, needs to be aware of transfer pricing rules. Under U.S. tax laws, the transfer pricing rules in IRC Section 482 are designed to prevent the artificial shifting of taxable
Taxation strategy is one of the key considerations when forming and funding a startup business. This article addresses key considerations of capital contribution tax on structuring a tax-free transaction for the stockholder(s) when contributing cash or property to a corporation in exchange for stock from the corporation. Such tax-free contribution is addressed under Internal Revenue Code Section 351.