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IRS offers gift tax safe harbor for contributions to Trump accounts
The guidance sets forth conditions for contributions to qualify for the annual gift tax exclusion and for donors to avoid filing gift tax returns.
IRS outlines AI risks, Circular 230 duties for tax practitioners
The IRS warned that AI’s risks — including fabricated outputs and data privacy concerns — require practitioners to verify results and follow existing Circular 230 rules on diligence, competence, and confidentiality.
About a quarter of callers to two IRS lines got poor service, TIGTA says
The Treasury Inspector General for Tax Administration estimated that about 1 million callers to two IRS customer service lines did not receive quality service.
IRS to merge tax practitioner offices despite AICPA opposition
The new Tax Professional Management Office will combine the Return Preparer Office and Office of Professional Responsibility functions under one structure, with the IRS saying their missions and oversight roles would remain unchanged.
Trust distributions: Timing, tax, and practical considerations
This article explains the basics of trust distributions, focusing on key concepts, relevant rules and elections, and planning choices that can help trustees manage taxes for both the trust and its beneficiaries.
Foreign employers’ FICA obligations: Key challenges and compliance strategies
A foreign employer’s duty to comply with U.S. payroll tax rules for employees who work in the United States can give rise to various issues.
Offer of Appeals conference is opportunity to dispute underlying liability
Taxpayers who refused to meet with IRS Appeals to contest their penalty liability were thereby precluded from doing so in a Collection Due Process or Tax Court proceeding, the court held.
Sec. 280E bars claim for refundable portion of ERC
The employee retention credit is among those prohibited under the section for taxpayers trafficking in federally controlled substances, the Tax Court held, finding against a marijuana dispensary business.
AICPA supports bills to limit BOI reporting to foreign-owned entities
The AICPA said the changes would ease the compliance load on CPAs who help small businesses navigate federal reporting rules.
AICPA submits nearly 200 recommendations for IRS guidance plan
The organization highlighted top technical issues across 10 areas and urged the IRS to prioritize tax simplification.
COVID-19 disaster relief case has implications for timely refund claims
National Taxpayer Advocate Erin Collins explained what affected taxpayers need to do in response to the Court of Federal Claims’ holding that a taxpayer’s refund claim filing deadline was automatically extended by Sec. 7508A(d)(1) due to the COVID-19 disaster declaration.
Demystifying reattribution: Disregarded payments and the FTC limitation
Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.
Navigating tax controversy strategies amid IRS operational challenges
Practitioners must leverage available technology, build effective communication strategies, and maintain comprehensive documentation of their interactions with the Service.
Tax ethical standards in data protection and reliance on tools
Case studies illustrate provisions for safeguarding client data and outline professional responsibilities under the AICPA Statements on Standards for Tax Services.
Frequently encountered controversy issues in M&A transactions
Procedural issues involving entity change in mergers and acquisitions can be managed by attentiveness and, in many cases, relief provisions.
Fifth Circuit rejects ‘passive-investor’ definition of limited partner
The Fifth Circuit, overruling the Tax Court, held that for purposes of the Sec. 1402(a)(13) exclusion from self-employment tax, “limited partner” means a partner in a limited partnership that has limited liability.
Assessment of tax for excess APTC payments is invalid
The Tax Court advised a taxpayer that filing a second petition would not allow another IRS Collection Due Process review.
Does an EIN/name mismatch invalidate a refund claim?
Arguments using the ‘informal claim doctrine’ and/or a taxpayer assistance order with the Taxpayer Advocacy Service may help taxpayers whose refund claims are stymied by a mismatch caused by an incorrect employer identification number.
Hedge funds: Tax structuring, planning, and compliance
Hedge funds may face tax issues of entity structuring, carried interest, management fee waivers, and trading-related rules. This article highlights planning strategies and compliance considerations as the IRS continues to increase its scrutiny of these investment vehicles.
Unlocking efficiency and reducing risk: How automation and AI are transforming tax reporting and withholding functions
Taxing authorities’ use of these new tools and capabilities requires corresponding adoption by tax professionals.
