September 2015

September 24, 2015

U.S. Enters First Agreements Implementing Automatic Information Exchange

The IRS announced that the United States has entered into agreements with Australia and the United Kingdom implementing procedures to automatically exchange financial account information pursuant to the Foreign Account Tax Compliance Act (FATCA).

September 24, 2015

Private Foundations Can Rely on More Practitioners When Making Good-Faith Determinations

The IRS has expanded the list of tax professionals who can be relied on when making a good-faith determination of a foreign grantee’s eligibility.

September 18, 2015

Final Rules Govern F Reorganizations

The final rules apply a concept called a potential F reorganization, allowing the many steps of a corporate reorganization to be examined together to see if the transaction qualifies to be an F reorganization.

September 17, 2015

IRS Issues Dividend-Equivalent Rules for Notional Principal Contracts and Equity-Linked Investments

The IRS issued regulations under Sec. 871(m) that govern withholding on dividend equivalents received by nonresident individuals and foreign corporations from sources within the United States.

September 16, 2015

Special Per-Diem Rates Issued for 2015–2016 Travel

The IRS issued per-diem rates for use in substantiating business expenses taxpayers incur while traveling away from home.

September 16, 2015

Charities Would Be Permitted to Issue Information Returns to Donors

Charities will be allowed to file information returns instead of providing contemporaneous written acknowledgment of charitable donations under proposed regulations issued by the IRS.

September 15, 2015

AICPA Expresses Concerns About Tax Return Preparer Legislation

The proposed grant of authority to the IRS to regulate all aspects of tax practice is overly broad, the AICPA said in a letter to the Senate Finance Committee.

September 14, 2015

Transfer-Pricing Arm’s-Length Standard and Transfers of Foreign Goodwill Clarified

Taxpayers will be required to consistently value transfer-pricing transactions for purposes of all Code sections under rules issued by the IRS.

September 9, 2015

Proposed Rules Govern Taxation of Gifts and Bequests From Covered Expatriates

Taxpayers who receive gifts or bequests from certain individuals who gave up their U.S. citizenship or residency will be subject to tax under rules proposed by the IRS on Wednesday.

September 8, 2015

IRS Final Rules Govern Required Minimum Contributions for Single-Employer Pension Plans

Rules issued by the IRS govern the determination of minimum funding requirements for single-employer pension plans and how to calculate the excise tax on underfunding these plans.

September 4, 2015

Rules Target Abuse of “Legging Out” of Foreign Currency Hedges

Final regulations issued on Friday clarify the tax treatment of certain terminations of qualified hedging transactions under Sec. 988.

September 2, 2015

Regulations Prevent CFCs From Using Partnerships to Avoid Sec. 956

The IRS issued temporary and proposed regulations governing the treatment of property held by a controlled foreign corporation in connection with certain transactions involving partnerships.

September 1, 2015

Employer Health Plans Must Cover Inpatient Hospital and Physician Services

The IRS added a requirement that employer-sponsored health plan benefits must include substantial coverage of inpatient hospital and physician services for the plan to count as providing minimum value.