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.
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Topics
International Tax
Cleansing the PFIC taint: Planning and pitfalls
This article focuses on the mechanics of the “cleansing” process and the associated advantages and potential pitfalls.
How a border tax could affect a company’s transfer pricing
The consideration of a border tax adjustment on goods imported may persuade multinational businesses to reevaluate their intercompany supply
chain, having transfer-pricing implications.
Developing a strategy to fight FBAR penalties
This article discusses the strategic considerations involved in mounting a defense to FBAR penalties based on a claim of a violation of the Administrative
Procedure Act.
International information return penalties remain a significant issue for taxpayers and advisers
This item explores the risks for certain delinquent or substantially incomplete international information returns.
Foreign-owned domestic disregarded entities: Why new reporting requirements?
Domestic disregarded entities wholly owned by foreign persons are now subject to new reporting obligations.
Tax planning for a nonresident entering the U.S. tax system
This item covers some of the key issues an immigrant faces after entering the U.S. tax system as a nonresident.
New reporting requirements for foreign-owned U.S. disregarded entities
The IRS issued regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for reporting, recordkeeping, and compliance purposes.
New regulations for Subpart F and CFC investment in U.S. property
The regulations address the treatment of U.S. properties held by CFCs in certain transactions involving partnerships.
Form 1040NR enters the 21st century
Nonresident filers can now file their 2016 Form 1040NR electronically.
Amazon wins multimillion dollar transfer-pricing dispute with IRS
The Tax Court held that Amazon.com had properly valued transfers of intangibles under a cost-sharing arrangement with its Luxembourg subsidiary.
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.
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.
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.
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.
New Developments in Outbound Transfers of Intangible Property
This article explores key recent developments that could impact proposed regulations as they become final.
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.
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.
FinCEN Grants Permanent Automatic Extensions for FBARs
Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.
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.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
