PRIMARY CONTACTS: Mary D. Richter CPA

外国衍生无形收入(FDII)

Onetax incentive that existsforthose in theexportbusiness isthereductionin tax rate onFDII, 或外国获得的无形收入. FDII is income that is generated on the export of intangible assets, such as patents or trademarks. The Internal Revenue Service allows for income generated on the sale of these assets, 受制于几个复杂的限制, to be taxed atthe13.125%而不是21%的公司税率.The rules regarding when and what qualifies for the FDII rate reduction are complex and seemingly always evolving.Schneider Downs’ tax professionals canprovideaidtobusinesses inmaking thedetermination as to whetherthey can benefit from a rate reduction on certain sales,help strategically plan new business ventures to take advantage of this significant rate reduction, and file the necessary forms and disclosures with the Internal Revenue Service annually.

利息国内国际销售公司(IC-DISC)

IC-DISC为出口商节省了大量所得税. Permanent tax savings are available to producers and distributors of U.S. made products used abroad.

Rely on your Schneider Downs’ internal tax professionals in exploring this great tax incentive. We can determine if your operating entity and business model is a good fit for this tax-advantaged vehicle.

Amnesty Programs

Non-willful delinquency in connection with disclosing your foreign assets happens all the time. These violations can lead to a variety of penalties and other serious consequences. Violation penalties vary. 一般来说，他们的起价是1万美元，甚至可能更高. 故意不提交FBAR或其他表格, for example, 你能多花100美元吗,000美元或国外账户余额的50%.

There are several existing IRS programs which can aid in fixing your non-compliance, and we can assist you in finding a tailored solution that makes sense for your situation. It is in your best interest to seek solutions proactively and disclose your foreign assets to the IRS. 国税局不会赦免你，除非你第一次和他们接触.

重要的是要强调时机是至关重要的, because the above IRS amnesty programs are currently available; however, 国税局可以随时取消它们. 目前有几个特赦计划:

拖欠的FBAR提交程序  

These procedures generally apply when the taxpayer did not fail to report any income and does not owe any tax, but non-willfully failed to file an FBAR or failed to include an account on a previously filed FBAR.

纳税人可以回去提交拖欠的fbar, and typically, 国税局不会对未提交fbar的人处以罚款. 我们可以帮助你评估你是否有资格参加这个项目.

拖欠的国际信息申报表提交  

Taxpayers who have identified the need to file delinquent international information returns who are not under a civil examination or a criminal investigation by the IRS and have not already been contacted by the IRS about the delinquent information returns should file the delinquent information returns through normal filing procedures.

Normally, if you provide a reasonable cause for the delay in your submission and don’t have any unpaid tax liability and the IRS will waive any penalties associated with late filing. 有时候，这种税收特赦是最好的办法. However, a thorough planning and analysis of all relevant facts is the key.

精简项目:国内和国外  

Did you miss reporting of your foreign accounts, investment, and income? The IRS has two great programs for non-willful delinquently filing taxpayers to become compliant: the domestic streamlined program and foreign streamlined program.

国内的精简程序要求:非任性, not being under IRS audit, 并在最近几年提交了纳税申报表. The potential 5% penalty could apply; however, this 5% penalty should be balanced against potentially large penalties associated with continuous noncompliance.

为国外简化程序, the main requirements are: non-residency and non-willfulness in failure to disclose foreign assets.  简化的外国手续不需要缴纳5%的罚款, 而且不需要事先提交纳税申报表.

在精简的程序中，不任性是至关重要的一部分. Determination of whether one’s conduct was non-willful can be highly technical, so it’s best to work with a qualified international tax professional.

关于施耐德唐斯税务顾问 

拥有全国最大的地区税务事务所之一, Schneider Downs Tax Advisors’ personal focus on clients and in-depth understanding of current issues ensures that clients are complying with tax filing requirements and maximizing tax benefits. Our industry knowledge and focus ensures delivery of technical tax strategies which can be implemented as practical business initiatives. Learn more at Tax Services.