(973) 507-9760 Paul@wiggmax.com

Generally companies and individuals required to file Form 5471 are subject to the current income inclusion rules for Subpart F income earned by the foreign corporation, whether the earnings are distributed by the foreign corporation or retained.

Calculating the amount of the earnings to be included in the U.S. shareholders income requires an understanding of Subpart F and an accounting for the foreign corporations earnings both in the current year and for all prior years in which the foreign corporation is treated as a controlled foreign corporation.

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The accounting may particularly difficult to create.  Accounting rules vary from country to country.  Although the AICPA is working to encourage the IRS to accept IFRS statements in lieu of U.S. GAAP, the IRS is still requiring the accounting to be according to U.S. GAAP.  This will generally require someone familiar with both accounting systems to translate the local accounting records for U.S. purposes.

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Maria Alexander
04-04-2018
Paul is an excellent attorney for small business owners like myself. He will make the appropriate research and make sure that the documents I have are all in working order and official. Paul always responds to phone my calls immediately, and he works fast whenever I need to have documents prepared quickly. His knowledge has helped me steer my business in the right direction and his advice is always on point and concise. I’ve had the pleasure of using Paul’s services for nearly a decade. During this time I had help with drafting and reviewing the following: several lease contracts, employee contracts, confidentiality and non-disclosure agreements, new client contract/liability waivers, US copyright electronic registrations, independent contractor agreements, website disclosure language, video release forms, and business registrations with the state. Having Paul as an attorney and being able to reach out to him whenever I have an emergency makes me more confident to run my business and I know that if I have a legal problem Paul will be there to help me.
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Oded Hecht
23-03-2018
Very good experience. I had some uncommon and large financial situations abroad as a US Citizen. I just wanted to make sure I am going about it legally and wisely. I am a business executive (Harvard B. School), having interacted with many top lawyers worldwide, and working with Paul was a pleasure and a wise choice. Beyond helping me professionally to solidify a winning strategy through his sound knowledge and experience, the interaction was exceptionally forthcoming and pleasant. I would recommend Paul without any hesitation!
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Dan Trolaro
16-10-2017
Took the time to listen, ask good questions, and provide good thoughts during initial phone call. Highly recommend giving him a call.
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Bill
07-08-2017
Mr. Wigg-Maxwell helped me out with a complicated international inheritance tax question. He was quick to respond with a knowledgeable answer. I would happily bring any future tax issues I have to Mr. Wigg-Maxwell for resolution.
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mathew gajewski
25-03-2018
Cool guy, extremely nice and knows his stuff.