Gerson Preston Partner Stuart Rohatiner Discusses International Tax Planning and Compliance at Harvard Club in New York City

Gerson Preston Partner Stuart Rohatiner Discusses International Tax Planning and Compliance at Harvard Club in New York City | Gerson Preston

The Harvard Club of New York is a private social club located in Midtown Manhattan, New York. The club is the sole club in New York City whose membership is restricted almost entirely to alumni and faculty of one university, Harvard University.

Stuart Rohatiner, a partner at Gerson Preston, recently spoke at the Harvard Club in New York City to a group of international tax advisors about the Internal Revenue Service’s four new examination initiatives in US International tax.

The four initiatives are as follows:

[1) Foreign Entities Doing Business in the United States. Are foreign entities with a US trade or business properly filing income tax returns and accurately reporting US income?

(2) Repatriation of Funds and Merger Transactions to Bring Profits into the US. Are US taxpayers properly declaring and reporting the funds/income received from offshore related party entities? Are some US taxpayers transactions too aggressive in repatriating funds into the US?

(3) Transfer Pricing. Are US taxpayer distributors recording a fair value in the US for the price of goods and/or services purchased from an offshore related party entity? Are US profits being artificially shifted offshore? Do you have a transfer pricing study in place based on the US Internal Revenue Code Section 482 Regulations?

(4) Offshore Voluntary Disclosure Program Follow-up. There are still approximately 6,000 US taxpayers that withdrew or were declined from Offshore Voluntary Disclosure Program that still haven’t come into US income tax compliance. The IRS will be contacting these taxpayers.

In addition, Stuart recently discussed this information with the South Dade Chapter of the Florida Institute of Certified Public Accountants (“FICPA”). The Internal Revenue Service intends to audit these tax areas in the upcoming period.

Contact Stuart Rohatiner at Gerson Preston to discuss your US international tax planning needs and compliance procedures.