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.
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Topics
International Tax
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.
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.
Look out for Sec. 956 inclusions
This article provides an introduction to Sec. 956 inclusions.
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.
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.
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.
Key aspects of maintaining a global workforce
Employees should have overarching guidance for their global assignment that includes international assignment agreements.
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.
Recent developments under FATCA, U.S. withholding tax, and global information reporting
This item looks at ongoing IRS guidance.
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.
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.
Rolling over equity when purchasing a Canadian company
This item discusses three options to achieve rollover equity when purchasing a Canadian company.
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.
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.
New Sec. 987 regulations affect partnerships
The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.
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.
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.
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.
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.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
