Simple Cost Sharing Agreement With Foreign Countries In Philadelphia
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An intercompany agreement, or sometimes referred to as an ICA, is a legal document that helps facilitate two or more companies owned by the same parent company in exchange for financing, goods, services, or other exchanges.
Recently, though, an ordinance signed by Philadelphia Mayor Jim Kenney in June 2022 adopts market-based sourcing for sales of services and intangibles. This change in sourcing methodology requires state-authorizing legislation and will be effective for the tax year after the year the state legislation is enacted.
Form 8802 should be submitted to the IRS by mail or fax. The mailing address and fax number are provided on the form instructions. The processing time for Form 8802 is typically 10 weeks, but it may take longer during peak filing periods.
Foreign Corporations Engaged in U.S. Trade or Business: Foreign corporations involved in any U.S. trade or business activities must also file Form 5472 if they engage in reportable transactions with a related party or a domestic related party.
A penalty of $25,000 will be assessed on any reporting corporation that fails to file Form 5472 when due and in the manner prescribed.
