Category: Uncategorized

The U.S. GILTI rules do not correspond to Australia’s CFC attribution rules for the purposes of the Australian hybrid mismatch rules: TD 2019/D12

The ATO has just released draft Tax Determination TD 2019/D12 in which it confirms that section 951A of the U.S. Internal Revenue Code (IRC) is...

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The U.S. Tax System: The TCJA’s attempt to move from Worldwide to Territorial

I wanted to take the chance to break down some of the big picture topics mentioned in the article, The Expansion of “United States” Taxpayers:...

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Trump Tax Reform Puts Domestic Business First and Foreign Founders Last

Written by: Peter Harper and Janpriya Rooprai Illustrations by: Janpriya Rooprai Peter heads CST Tax Advisors in North America and a member of the global...

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US Market Entry Guide: Top 10 issues to consider

For many international business owners, the US market is the holy grail of consumer markets. Technology is making it easier than ever to incorporate and...

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OVDP to end – If you have intentionally been non compliant with US taxes the time to act is now!

In the publication featuring the Tax Specialist in February 2017 titled “Nowhere to Hide – An Update on Remediation Options for U.S. Taxpayers with Australian...

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The US will not be my 1st Choice as a holding company jurisdiction, will it be yours?

In a whitepaper, that I had published in the Tax Specialist in April of 2018, I made the bold assertion that people may start looking...

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What is a check the box election and should a foreign corporation make one?

In our whitepaper, “United States entity considerations in the trump era” we outlined how the check the box regime can impact Australian businesses. While that...

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I have an online business selling products to US customers – am I required to pay tax in the US?

In our US Market Entry Guide we talked about the timing and drivers for establishing an entity in the US. We are often asked by...

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