International Tax

Topics

March 20, 2020

Final regulations address covered assets acquisition rules

The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.

March 12, 2020

Foreign gifts: A common example of undisclosed foreign transactions

Here’s what may happen when a foreign gift has not been disclosed.

March 1, 2020

Crime doesn’t pay — and may be taxable under Subpart F

One potentially important component of Subpart F
income under Sec. 952(a)(4) is illegal bribes, kickbacks, or other payments made by or on behalf of a CFC to a foreign government official, employee, or agent.

March 1, 2020

Country-by-country reporting: Considerations facing US multinationals

As the OECD member states plan to review the
CbC framework in 2020, this discussion highlights several common issues large U.S. MNEs may face.

March 1, 2020

IRS issues guidance on BEAT

The IRS issued detailed guidance on the Sec. 59A base-erosion and anti-abuse tax (BEAT), which was added to the Code by the law known as the Tax Cuts and Jobs Act.

February 1, 2020

Update on OECD’s proposals: Pillars 1 and 2

Issues raised in pillars 1 and 2 of the OECD consultation documents resemble issues being addressed at the state and local tax level in the United States.

February 1, 2020

Cross-border M&As post-TCJA: Three things advisers should know

This item highlights three often overlooked or misunderstood factors potentially disrupting international transactions.

January 1, 2020

New US duties on certain EU and Chinese goods

This item discusses punitive tarriffs.

January 1, 2020

Relief procedures for certain people planning to renounce US citizenship

The procedures allow qualifying former U.S. citizens who have relinquished U.S. citizenship to comply with their U.S. income tax and reporting obligations without paying any unpaid taxes and penalties.

January 1, 2020

Unintended CFC downward attributions get safe harbor

U.S. shareholders who own stock in foreign corporations were given a safe harbor by the IRS, making it easier for them to establish that they are not shareholders in a controlled foreign corporation.

December 17, 2019

Final regs. issued on foreign tax credits

The IRS officially released final regulations providing guidance on determining foreign tax credits. The regulations include changes necessitated by the law known as the Tax Cuts and Jobs Act.

December 3, 2019

BEAT regs. are finalized, new regs. are proposed

The IRS issued detailed guidance on the Sec. 59A base-erosion and anti-abuse tax (BEAT), which was added to the Code by the law known as the Tax Cuts and Jobs Act.

November 1, 2019

IRS issues Q&As on Sec. 965 transfer and consent agreements

The IRS released guidance to further recap and clarify
the rules for transfer and consent agreements.

November 1, 2019

Proposed rules would govern digital content and cloud computing

The IRS proposed regulations to clarify how to classify transactions involving digital content and cloud computing.

October 1, 2019

CFC downward attributions get safe harbors

U.S. shareholders who own stock in foreign corporations were given a safe harbor by the IRS, making it easier for them to establish that they are not shareholders in a controlled foreign corporation, or CFC.

October 1, 2019

The TCJA: Double taxation for US citizens living abroad

Individuals, who are not afforded the benefit of using indirect foreign tax credits, are unable to reduce their Sec. 965 liability with foreign taxes generated at the foreign company level.

October 1, 2019

Demystifying the new international E&P rules

This discussion provides a summary of some of the basic previously taxed earnings and profits ordering rules likely to apply to distributions made by controlled foreign corporations .

October 1, 2019

US MNCs facing implications of economic (vs. physical) nexus

This item summarizes the complexities of a digitalized economy for MNCs and considers the
multifaceted implications to U.S. MNCs with respect to financial statements and tax reporting.

September 9, 2019

IRS offers expatriate tax relief

The IRS announced procedures to allow certain individuals who have renounced their US citizenship to get into compliance with their U.S. tax obligations and obtain relief for back taxes.

September 1, 2019

Sec. 1446(f) proposed regs.: Withholding on transfers of partnership interests

Partnerships will need to establish procedures to deal with secondary withholding in the event that
transferees do not withhold or collect the appropriate documentation.