International Tax

Topics

August 1, 2017

The challenge of maximizing the foreign tax credit on qualified dividends

This item illustrates how challenging it can be to
use foreign tax credits on qualified dividends.

August 1, 2017

Wells Fargo wins partial victory on STARS transaction

The Tax Court held that the loan portion of a STARS transaction was not a sham but that the company was subject to tax penalties.

July 1, 2017

New Sec. 987 regulations affect partnerships

The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.

July 1, 2017

Hidden insurance excise tax obligations arising from corporate chargebacks

When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.

July 1, 2017

Sales by foreign governments of partnerships that hold U.S. real property

The gain on a sale could be subject to U.S. federal income tax.

July 1, 2017

Adjustments of foreign capital gains and losses for the foreign tax credit

This article discusses some requirements of Form 1116 and the adjustments’ directions as laid out in Publication 514.

July 1, 2017

Due dates for returns of foreign corporations

To qualify for a certain automatic extension, the
taxpayer can attach a statement to a return showing that it is a foreign corporation that maintains an office or place of business in the United States.

July 1, 2017

Departing aliens and the sailing permit

It is important to understand compliance requirements should the IRS begin using the sailing permit to aid its collection efforts.

June 1, 2017

The European mini one-stop shop: A model for future indirect tax compliance?

This item covers how MOSS operates and explains why certain provisions need to be amended.

June 1, 2017

Amazon wins transfer-pricing case

The Tax Court held that the IRS’s determination, using a discounted-cashflow method, of the value of a CSA buy-in payment for Amazon.com’s transfer to
a subsidiary of the right to use certain preexisting intangible assets in Europe was arbitrary, capricious, and unreasonable.

June 1, 2017