International Tax

Topics

June 28, 2018

Failure to abandon U.S. residency leads to tax liability

A German citizen’s failure to establish that he was a resident of Germany meant he was a “covered expatriate” liable for tax on stock sale gains.

June 5, 2018

Sec. 965 transition tax penalty relief issued

The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings.

June 1, 2018

The new GILTI and repatriation taxes: Issues for flowthroughs

In many instances, the new repatriation tax will produce harsh results for flowthrough taxpayers.

May 1, 2018

Which taxpayers are potentially subject to the new ‘BEAT’?

Imposition of a base-erosion and anti-avoidance tax adds fresh complexity to the calculation of transfer-pricing tax and accounting results.

May 1, 2018

Sec. 267A: Certain related-party amounts paid or accrued in hybrid transactions or with hybrid entities

It appears that Sec. 267A allows a taxpayer to deduct a disqualified related-party amount if the amount is not paid pursuant to a hybrid transaction or paid by or to a hybrid entity.

April 26, 2018

The Offshore Voluntary Disclosure Program and cryptocurrency

The IRS is ending the Offshore Voluntary Disclosure Program just as its enforcement of cryptocurrency compliance increases.

April 1, 2018

Filing deadline for 2017 FBARs same as for individual tax returns

FinCEN issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts.

March 14, 2018

Offshore Voluntary Disclosure Program to end in September

The IRS announced that it is closing the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.

March 8, 2018

The physical presence test for excluding foreign earned income

Under Sec. 911, a U.S. citizen whose tax home is in one or more foreign countries, who spends enough there, can exclude a certain amount of foreign earned income.

March 1, 2018

External reviewer independence requirements and the 2017 QI Agreement

The IRS published a FATCA FAQ to establish a
temporary standard of independence until it can provide comprehensive guidance.

March 1, 2018

Coca-Cola entitled to credits for overpaid Mexican taxes

Although a company might in the future receive a refund of foreign taxes paid, it was entitled to claim
foreign tax credits.

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.