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.
The Tax Court held that Amazon.com had properly valued transfers of intangibles under a cost-sharing arrangement with its Luxembourg subsidiary.
The IRS issued temporary regulations designed to prevent taxpayers from misapplying the Sec. 901(m) statutory disposition rule in certain cases when a foreign asset is disposed of.
FinCEN's six-month extension will be automatic each year, and taxpayers do not have to request extensions.
The IRS issued regulations that govern certain transfers of goodwill and going concern value to foreign corporations in nonrecognition transactions under Sec. 367.
This item provides an overview of applying U.S. domestic tax law and a U.S. income tax treaty to a foreign corporation.
This article explores key recent developments that could impact proposed regulations as they become final.
The IRS issued regulations aimed at preventing controlled foreign corporations from using partnerships to avoid Sec. 956, which requires income inclusion for certain investments in U.S. property.
IRS describes regulations it intends to issue identifying as foreign tax credit splitter arrangements certain transactions undertaken by corporations in anticipation of foreign-initiated income tax adjustments.
Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.