This item discusses three options to achieve rollover equity when purchasing a Canadian company.
This item illustrates how challenging it can be to use foreign tax credits on qualified dividends.
The Tax Court held that the loan portion of a STARS transaction was not a sham but that the company was subject to tax penalties.
This article discusses some requirements of Form 1116 and the adjustments’ directions as laid out in Publication 514.
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
To qualify for a certain automatic extension, the taxpayer can attach a statement to a return showing that it is a foreign corporation that maintains an office or place of business in the United States.
The gain on a sale could be subject to U.S. federal income tax.
The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.
It is important to understand compliance requirements should the IRS begin using the sailing permit to aid its collection efforts.
The Tax Court held that the IRS’s determination, using a discounted-cashflow method, of the value of a CSA buy-in payment for Amazon.com’s transfer to a subsidiary of the right to use certain preexisting intangible assets in Europe was arbitrary, capricious, and unreasonable.
This article focuses on the mechanics of the “cleansing” process and the associated advantages and potential pitfalls.
This item covers how MOSS operates and explains why certain provisions need to be amended.
The consideration of a border tax adjustment on goods imported may persuade multinational businesses to reevaluate their intercompany supply chain, having transfer-pricing implications.
This article discusses the strategic considerations involved in mounting a defense to FBAR penalties based on a claim of a violation of the Administrative Procedure Act.
This item covers some of the key issues an immigrant faces after entering the U.S. tax system as a nonresident.
The IRS issued regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for reporting, recordkeeping, and compliance purposes.
The regulations address the treatment of U.S. properties held by CFCs in certain transactions involving partnerships.
Domestic disregarded entities wholly owned by foreign persons are now subject to new reporting obligations.
This item explores the risks for certain delinquent or substantially incomplete international information returns.
Nonresident filers can now file their 2016 Form 1040NR electronically.