専門分野
International tax covers the complex rules governing cross-border income, foreign business operations, and multi-country tax obligations. As businesses expand globally and individuals live or earn across borders, the stakes of getting international tax wrong — double taxation, penalties, missed treaty benefits — grow quickly. The right advisor navigates these rules proactively so you're compliant and tax-efficient.
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international taxに関するよくある質問。
What is a tax treaty and how does it help me?
Tax treaties are bilateral agreements between countries that determine how cross-border income is taxed and prevent double taxation. They can reduce withholding tax rates on dividends, interest, and royalties, and clarify which country has primary taxing rights. Knowing which treaties apply to your situation can significantly reduce your global tax burden.
What is a Controlled Foreign Corporation (CFC) and do I need to worry about it?
A CFC is a foreign company where US persons own more than 50%. US shareholders of CFCs face complex reporting requirements (Form 5471) and may owe US tax on undistributed foreign earnings under the GILTI and Subpart F rules. If you own or control a foreign company, you almost certainly need specialist advice.
What is FBAR and who needs to file it?
FBAR (Foreign Bank Account Report) is required for US persons who have financial interest in or signature authority over foreign bank accounts with an aggregate balance exceeding $10,000 at any point during the year. Penalties for non-filing are severe — up to $10,000 per violation for non-willful failures.
I'm hiring contractors in other countries. What are my tax obligations?
It depends on the country and the nature of the relationship. In some jurisdictions, consistent use of contractors can create a permanent establishment — triggering local corporate tax obligations. Others have specific withholding requirements on payments to non-residents. An international tax advisor can assess your specific exposure before you hire.