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IRS Targets Non-U.S. Vessel Owners in Gulf of Mexico
Shawn O’BrienJackson Walker L.L.P.
(713) [email protected]
IRS Targets Non-U.S. Vessel Owners in Gulf of Mexico
Shawn O’BrienJackson Walker L.L.P.
(713) [email protected]
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IRS International Enforcement EffortIRS International Enforcement Effort
Foreign Financial Accounts Held by U.S. Persons
U.S. Activity of Non U.S. Persons
U.S. Permanent Establishments by Foreign Companies
Transfer Pricing of Inter-Company Transactions of Multi-National Companies
Foreign Financial Accounts Held by U.S. Persons
U.S. Activity of Non U.S. Persons
U.S. Permanent Establishments by Foreign Companies
Transfer Pricing of Inter-Company Transactions of Multi-National Companies
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IRS Targets Gulf of MexicoIRS Targets Gulf of Mexico
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IRS InitiativeU.S. Outer Continental Shelf Activities
IRS InitiativeU.S. Outer Continental Shelf Activities
Three Categories of Activities Targeted:
(1) Contractors performing seismic, testing, drilling repair and salvage services;
(2) Vessel Operators transporting supplies and personnel; and
(3) Bareboat or Time Charter vessels.
Three Categories of Activities Targeted:
(1) Contractors performing seismic, testing, drilling repair and salvage services;
(2) Vessel Operators transporting supplies and personnel; and
(3) Bareboat or Time Charter vessels.
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IRS Research of OCS ActivitiesIRS Research of OCS Activities
U.S. State Department Records – B-1 OCS Visas
U.S. Coast Guard Filings
Internet Sites -
Company WebsitesBlogs Tracking Vessel Movement
U.S. State Department Records – B-1 OCS Visas
U.S. Coast Guard Filings
Internet Sites -
Company WebsitesBlogs Tracking Vessel Movement
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U.S. Activity Subject to TaxU.S. Activity Subject to Tax
Income Tax – Form 1120 FPayment received for services performed on
OCS is considered taxable income under U.S. Internal Revenue Code
Payments to a Foreign company may require withholding by Payor using a Form 1042
Employment Tax – Forms 940 and 941Foreign Crew compensation taxablePayor/Employer may be required to withhold
Income Tax – Form 1120 FPayment received for services performed on
OCS is considered taxable income under U.S. Internal Revenue Code
Payments to a Foreign company may require withholding by Payor using a Form 1042
Employment Tax – Forms 940 and 941Foreign Crew compensation taxablePayor/Employer may be required to withhold
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IRS CorrespondenceIRS Correspondence
IRS “Soft Letter” Regarding Activities
IRS Information Document Request
Proforma Tax Returns if Non Compliant
IRS “Soft Letter” Regarding Activities
IRS Information Document Request
Proforma Tax Returns if Non Compliant
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How to Navigate IRSHow to Navigate IRS
Do Not Ignore the Issue
Treaty May Lessen the Blow of Taxation
Communicate with IRS Agent Through a Representative
Become Compliant with IRS Filing Requirements
Do Not Ignore the Issue
Treaty May Lessen the Blow of Taxation
Communicate with IRS Agent Through a Representative
Become Compliant with IRS Filing Requirements
