International Tax

Topics

March 1, 2018

Transnational tax information reporting: A guide for the perplexed

This article alerts the practitioner to when an information return may be necessary.

February 8, 2018

Tax treaty benefits for U.S. citizens and residents

Treaties may have exceptions to saving clauses that benefit U.S. persons in terms of their U.S. income taxes.

February 5, 2018

FinCEN announces filing deadline for 2017 FBARs

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

February 1, 2018

Congress enacts tax reform

This column summarizes the federal tax law changes under reform enacted in December.

February 1, 2018

How inbound real estate investors are treated under the Tax Cuts and Jobs Act

This column discusses the portions of the act likely to affect the typical inbound real estate investment structure.

January 1, 2018

Implementation of certain parts of Sec. 871(m) regs. delayed a year

This extension continues the status quo for a number of provisions through 2018 and provides a one-year extension on many transition aspects.

January 1, 2018

U.S. parent’s CFCs held U.S. property under Sec. 956 as result of intercompany transactions

Tax Court granted the government’s motion for summary judgment that intercompany transactions
between a U.S. parent’s CFCs and its domestic subsidiaries resulted in the CFCs holding U.S. property.

January 1, 2018

Pilot grounded on foreign income exclusion

A pilot who lived at a hotel in South Korea while there for his job was not entitled to the foreign earned income exclusion because he had not proved that he was a bona fide resident.

December 1, 2017

Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 3

This last article in a three-part series contains an analysis of the tax reporting of the net income distribution to a U.S. beneficiary of a foreign nongrantor trust.

November 7, 2017

Foreign income provisions in the Tax Cuts and Jobs Act

The House’s tax reform bill would make many changes to the taxation of US companies’ foreign subsidiaries.

November 1, 2017

Look out for Sec. 956 inclusions

This article provides an introduction to Sec. 956 inclusions.

November 1, 2017

Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 2

Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.

October 1, 2017

Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 1

Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.

October 1, 2017

Offshore Voluntary Disclosure Program: Limitation period on credits or refunds

This item explains how the statute of limitations may affect a taxpayer when claiming a refund or credit on an overpayment through amended tax returns while under the OVDP.

October 1, 2017

Key aspects of maintaining a global workforce

Employees should have overarching guidance for their global assignment that includes international assignment agreements.

October 1, 2017

Intragroup transfers of U.S. subsidiaries triggering withholdable dividends

For reasons other than U.S. income tax, these transactions could be structured as sales of U.S. stock among foreign affiliates.

September 1, 2017

Recent developments under FATCA, U.S. withholding tax, and global information reporting

This item looks at ongoing IRS guidance.

September 1, 2017

Treaty benefits on FDAP income derived by hybrid entities

This item discusses treaty benefit limitations on U.S.-source FDAP income with respect to hybrid
entities and procedural requirements of obtaining treaty benefits.

September 1, 2017