Category: News & Blog

Published in the Journal of International Taxation, Thomson Reuters, Vol. 35, No. 4, April 2024. Cost Allocation Base Selection for Transfer Pricing Purposes By Anthony Malik INTRODUCTION The successful implementation of a cost-based transfer pricing policy necessitates the group of companies to devise robust internal cost allocation methodologies. The reasonability of the cost allocation method […]

Published in Tax Notes International, Tax Analysts, Vol. 111, No. 6, August 7, 2023. The Creditability of Contemporaneously Paid Foreign Taxes By Anthony Malik INTRODUCTION Taxpayers earning foreign source income can satisfy their foreign tax liabilities in one of several different ways depending on the character of the income earned, the taxpayer’s level of foreign […]

Published in the Journal of Financial Planning, Financial Planning Association, Vol. 35, No. 10, October 2022. Essential Tax Rules of Cross-Border Gifting By Anthony Malik Introduction Strategic gift planning, done usually to minimize or eliminate the estate and expatriation[1] taxes, is firmly within the purview of tax and financial advisors. The vast majority of gifting […]

Published in the Journal of International Taxation, Thomson Reuters, Vol. 33, No. 3, March 2022. Timing the Creditability of Accrued Foreign Taxes By Anthony Malik INTRODUCTION Compliance-oriented tax professionals are—in many cases, for very good reason—most likely to first turn toward material published by the Internal Revenue Service (“IRS”) via instructions to tax forms and […]

Reprinted with permission from the California Tax Lawyer, The State Bar of California—Taxation Section. An Inquiry into the Factors Aiding Clemency for Foreign Corporations Requesting Protective Tax Return Filing Deadline Waivers By Anthony Malik[1] INTRODUCTION Foreign corporations (“FCs”) often have varying degrees of U.S. business activities which in turn subject them to varying degrees of […]

Tony Malik of Point Square Consulting was busy meeting top government tax policy advisors and lawmakers in Washington, DC last week. Very simply, the major items Point Square Consulting advocated for during the deliberations included: Expanding the rights of taxpayers appointing legal representatives. Defining realistic goals for the IRS in light of recent tax reform and budget cuts. […]

Tony Malik, our firm’s Principal Consultant, was busy meeting with eminent tax policy advisors and legislative directors on Capitol Hill in Washington, DC last week. Some of the critical items Point Square Consulting advocated for during the deliberations included: Elimination of severe international tax penalties imposed on taxpayers for minor instances of noncompliance with various tax laws. Electronic delivery of the […]

Tony Malik of our firm has been invited by the Atlanta World Trade Center to present an overview of the U.S. international tax system. As guest speaker, Tony will focus on the tax rules and planning considerations for cross-border businesses. Scheduling details of the event are as follows: Date: Tuesday, March 14, 2017 Time: 8:00AM Location: City Club of Buckhead, 3343 Peachtree Road […]

Tony Malik of our firm has been invited by the North Atlanta Chapter of the Georgia Society of CPAs to speak on the practical international tax implications of repatriating offshore profits. As guest speaker for the evening, Tony will cover discussion points including the income classification rules, foreign tax credit considerations, and the interplay of international tax treaties […]

We proudly announce that the October/November 2016 edition of the prestigious Journal of Tax Practice and Procedure features the following article authored by our Principal Consultant, Tony Malik. The article examines U.S. shareholder taxation upon their accessing foreign corporations’ earnings in the form of cash dividends. Taxation of Dividends from Foreign Corporations Reprinted with permission from the Journal of Tax Practice […]