Franchelly Diaz Colon, Author at WilkinGuttenplan

Articles International Tax Mergers & Acquisitions Tax Services

Cross-Border M&A Readiness: International Tax Risks

Cross-border M&A readiness starts long before a company goes to market. Companies with international operations that haven't addressed their cross-border…

Franchelly Diaz ColonJune 30, 2026

Articles International Commerce Group International Tax

IRS Clarifies Form 5472 Penalty Relief

The IRS Office of Associate Chief Counsel (International) recently issued Chief Counsel Advice (CCA) 202617012 addressing when small foreign-owned corporations…

Franchelly Diaz ColonJune 2, 2026

Articles Tax Services Technology

New Final Regulations and Proposed Regulations on Digital Content and Cloud Transactions

On January 14, 2025, the Department of Treasury and the IRS issued final regulations that clarify how cloud transactions are…

Franchelly Diaz ColonJanuary 20, 2025

Articles International Tax Trusts & Estates

The IRS Halts Automatic Penalties Related to Forms 3520 and 3520-A

What are Forms 3520 and 3520-A? Form 3520, Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain…

Franchelly Diaz ColonNovember 5, 2024

Articles International Commerce Group International Tax

No “Moore” Debates: 2017 Mandatory Repatriation Tax Upheld by Supreme Court

What is the Moore v. United States case about? Charles and Kathleen Moore (the “Moores") were subject to Internal Revenue…

Franchelly Diaz ColonJune 24, 2024

Articles Business Tax International Commerce Group International Tax

Action Required for U.S. Business Entities with Foreign Ownership

Action Required for U.S. Business Entities with Foreign Ownership BEA BE-12 Survey Filing Required by May 31, 2023 Like the…

Franchelly Diaz ColonApril 4, 2023

Articles Business Tax International Commerce Group International Tax

The Flexible U.S. Tax Entity Classification Election System

U.S. Entity Taxation and Check-The-Box Election In the U.S. tax system, an entity can be thought of as either a…

Franchelly Diaz ColonMarch 29, 2023

Articles International Commerce Group International Tax Tax Services

Have You Considered Moving to Puerto Rico?

Have you considered moving to Puerto Rico? Warm weather, beautiful beaches, and tax savings... this sounds perfect. So, what are…

Franchelly Diaz ColonOctober 28, 2022

Articles International Commerce Group International Tax Tax Services

The Basics of Transfer Pricing

What is transfer pricing? Broadly, transfer pricing is how profit is allocated among commonly controlled entities. For U.S. federal income…

Franchelly Diaz ColonMay 6, 2022