Last week we posted about the taxation of Australian superannuation funds potentially being treated as social security under the Australia-U.S Income Tax Treaty. The post explicitly assumed, for argument’s sake, that “superannuation guarantee” was considered part of the social security system of Australia.… Read more
Is it a good idea to set up a Belize IBC to sell products to U.S. customers thru Amazon FBA? Perhaps not.
Let’s assume the situation is as follows: An individual (let’s call her Jane) resides in a foreign country — say, for example, Australia.… Read more
Last week, the Tax Court released an important opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, where the court declined to follow Rev. Rul. 91-32.
For more than 25 years the IRS has maintained that gain on a foreign partner’s disposition of an interest in a partnership that conducts business in the U.S.… Read more