International Tax

Topics

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

State tax considerations for foreign companies with inbound U.S. investments

Non-U.S. taxpayers generally are surprised by the degree of complexity involved in complying with U.S. state and local taxes.

August 1, 2017

Rolling over equity when purchasing a Canadian company

This item discusses three options to achieve rollover equity when purchasing a Canadian company.

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