A check-the-box election may either eliminate or impose U.S. tax and compliance burdens for foreign owners.
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Topics
International Tax
Planning for domestication transactions
Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special rules and considerations.
Effect of the new pro rata share rules
Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.
Recent regulations affect US real estate investments
Proposed and final regulations under Secs. 897 and 892, respectively, provide relief from lookthrough attribution for domestically controlled real estate investment trusts and U.S. taxation of noncommercial investments by foreign governments.
Tax implications of US residency for foreign nationals
Foreign entrepreneurs and others entering the United States, whether for short-term visits or permanently, should be mindful of the complex U.S. income tax and foreign information-reporting rules that may apply to them.
The new CFC tax landscape after OBBBA
H.R. 1, P.L. 119-21, known as the One Big Beautiful Bill Act, introduced significant changes to the controlled foreign corporation rules that affect U.S. taxpayers with foreign corporate interests. Two key amendments introduced under Section 70353 of the OBBBA are particularly noteworthy.
VAT challenges in AI product development
Artificial intelligence may incrementally become a product’s component until it crosses a threshold into being a digital service subject to value-added tax.
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.
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.
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.
IRS issues guidance on treaty application to reverse foreign hybrids
The IRS provides guidance on whether these entities qualify under a U.S. federal income tax treaty for relief from the branch profits tax.
Key international tax issues for individuals and businesses
U.S. persons abroad and foreign persons living in or with connections to the United States may have responsibilities for filing any of an array of returns and information forms.
IRS announces prop. regs. on international tax law provisions in OBBBA
The proposed regulations will deal with changes included in H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act.
QSBS gets a makeover: What tax pros need to know about Sec. 1202’s new look
New legislation has expanded the already advantageous provisions for gain exclusion from a sale of qualified small business stock.
IRS ruling clarifies treatment of R&D when computing the FDII deduction
IRS rules research and development services U.S. entities provide to their foreign parent principal company may be characterized entirely as foreign-derived deduction eligible income purposes.
Global tax deal could hurt US companies, says letter requesting OECD guidance
A letter from the Association of International Certified Professional Accountants addresses guidance and recommendations on the Pillar Two framework co-existing with U.S. tax rules for U.S. multinational enterprises in a side-by-side system to the OECD.
AI is transforming transfer pricing
Mimi Song, COO, Exactera, discusses how AI can improve transfer pricing compliance.
IC-DISC commission payment provisions
Interest charge domestic international sales corporations offer tax benefits, but taxpayers must carefully follow their requirements.
The role of REITs for foreign investors in US real estate
Foreign investors with U.S. real property interests seeking to reduce their tax burden may find real estate investment trusts useful.
Qualified small business stock: The trap for foreign entities restructuring into a US corporation
A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
