International Tax

Topics

March 1, 2017

IRS Issues Final Sec. 367 Regulations on Transfers of Intangibles

The IRS issued regulations that govern certain transfers of goodwill and going concern value to foreign corporations in nonrecognition transactions under Sec. 367.

March 1, 2017

FBARs Are Automatically Extended Until Oct. 15, FinCEN Announces

FinCEN’s six-month extension will be automatic each year, and taxpayers do not have to request extensions.

March 1, 2017

Sec. 901(m) Temporary Regulations Apply to Covered Asset Acquisitions

The IRS issued temporary regulations designed to prevent taxpayers from misapplying the Sec. 901(m) statutory disposition rule in certain cases when a foreign asset is disposed of.

February 1, 2017

The Authorized OECD Approach to a U.S. Permanent Establishment

This item provides an overview of applying U.S. domestic tax law and a U.S. income tax treaty to a foreign corporation.

January 1, 2017

New Developments in Outbound Transfers of Intangible Property

This article explores key recent developments that could impact proposed regulations as they become final.

January 1, 2017

IRS Plans Regs. on Sec. 909 Foreign Tax Credit Splitter Arrangements

IRS describes regulations it intends to issue identifying as foreign tax credit splitter arrangements certain transactions undertaken by corporations in anticipation of foreign-initiated income tax adjustments.

January 1, 2017

Regulations Govern Treatment of Controlled Foreign Corporations Using Partnerships

The IRS issued regulations aimed at preventing controlled foreign corporations from using partnerships to avoid Sec. 956, which requires income inclusion for certain investments in U.S. property.

December 19, 2016

FinCEN Grants Permanent Automatic Extensions for FBARs

Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.

December 15, 2016

Final Rules on Sec. 367 Transfers of Intangibles Apply Retroactively

The IRS issued regulations finalizing proposed rules issued in 2015 that govern certain transfers of goodwill and going concern value to foreign corporations in nonrecognition transactions under Sec. 367.

December 6, 2016

Rules Govern Covered Asset Acquisitions Under Sec. 901(m)

The IRS issued temporary regulations that are designed to prevent taxpayers from misapplying the Sec. 901(m) statutory disposition rule in certain cases when a foreign asset is disposed of.

December 1, 2016

An Update on Foreign Financial Account Reporting

This article revisits the reporting requirements
for an FBAR and highlights FBAR reporting requirements that differ from those of Form 8938.

November 10, 2016

Brexit: Major Tax Changes for Global Businesses

Many areas of shared tax law and practice may be affected, including indirect and direct taxes.

November 2, 2016

IRS Finalizes Rules on Controlled Foreign Corporations

The IRS issued regulations aimed at preventing controlled foreign corporations from using partnerships to avoid Sec. 956, which requires income inclusion for certain investments in U.S. property.

November 1, 2016

Should the United States Enact a Patent Box?

Many countries have implemented preferential
tax systems to bolster incentives to keep research and innovation activities onshore.

November 1, 2016

Ethics and Risk Issues in FBAR Preparation

A number of ethics and risk management issues must be considered when preparing and filing FinCEN Form 114.

October 14, 2016

Earnings-Stripping Rules Make Many Changes From Proposed Regs.

The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.

October 1, 2016

Online Poker Accounts Not Subject to FBAR Reporting

The Ninth Circuit held that a taxpayer’s accounts with two foreign-based online poker sites were not bank accounts that a taxpayer must report on an FBAR.

October 1, 2016

Foreign Information Returns, Income Tax Returns, and Civil Penalties

To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income
tax return.

October 1, 2016

IRS Revises Forms 1042-S and W-8BEN-E for 2016

The IRS issued 2016 versions of Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, and Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities).

October 1, 2016

Tax Court Needs to Do More Work in Interpreting Totalization Agreement

The meaning of the terms “amend” or “supplement” must be determined in light
of the full text of a social security totalization agreement and the shared expectations of the
contracting governments.