International Tax

Topics

October 1, 2016

State and Local Tax Considerations for Inbound Foreign Entities

Foreign entities not engaged in a U.S. trade or business, not deemed to have a permanent establishment, or that have claimed a federal treaty exemption may still be subject to state and local income taxes.

October 1, 2016

Entity Classification Within the Foreign Context and the Tax Consequences of Sec. 987

Making an election under the check-the-box regulations allows certain entities with a single owner to be treated as disregarded entities or branches of the U.S. owner for U.S. tax purposes.

September 15, 2016

IRS Restricts Foreign Tax Credit Splitter Arrangements

The IRS issued guidance prohibiting corporations from taking foreign tax credits for taxes without repatriating the earnings to the United States.

September 1, 2016

IRS Finalizes Country-By-Country Reporting Regulations

The IRS issued final regulations implementing new country-by-country reporting requirements.

August 1, 2016

The Evolution of U.S. Reporting Requirements for Canadian Retirement Accounts

This item explains the evolution of the IRS reporting requirements for Canadian registered retirement savings plans and registered retirement income funds.

August 1, 2016

Foreign-Owned Disregarded Entities Would Be Required to Report

U.S. disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the IRS.

August 1, 2016

Taxpayer Wins Big in Transfer-Pricing Dispute

The Tax Court held that the IRS had abused its discretion in reallocating income related to intercompany licenses for the intangible property to manufacture medical devices from a Puerto Rican company to its U.S. parent company.

August 1, 2016

Considerations on Whether to Check the Box for Foreign Subsidiaries

The decision affects both the timing and ultimate U.S. taxation of foreign income.

July 1, 2016

Issues Involving the Interplay of Subpart F Income Recapture Account and Sec. 956 Inclusion

Treating a Sec. 956 inclusion as not a distribution for purposes of Regs. Sec. 1.952-1(f)(2)(iii) leads to unintended results under certain fact patterns.

June 30, 2016

Final Rules Govern U.S. Country-by-Country Reporting

The IRS issued final regulations requiring the ultimate parent entity of a multinational enterprise group with revenue of $850 million or more in the preceding accounting period to file Form 8975, Country-by-Country Report.

June 1, 2016

IRS Proposes Earnings-Stripping Rules, Issues Other Inversion Guidance

A package of proposed and temporary regulations are designed to reduce the tax benefits and incentives for corporate inversions.

June 1, 2016

Foreign Currency Straddles and Transactions Present Complex Tax Issues

Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.

June 1, 2016

Form 5471 Substantial Compliance: What Does It Mean and Why Is It Critical?

A required person who fails to file the form or files a late or incomplete form is subject to substantial monetary penalties.

June 1, 2016

Global Trends: On the Brink of a New VAT Revolution?

The world is entering a new “VAT revolution” marked by the role of technology in the way people consume goods and services and how tax authorities administer the tax.

June 1, 2016

Are Problems Looming for FATCA and the “Reciprocal” IGA?

The Treasury Department may soon experience relationship problems with certain countries that have entered into intergovernmental agreements under FATCA.

June 1, 2016

Adopting BEPS in the EU: The Impact of the EC’s Anti Tax Avoidance Package

This item describes certain significant areas where the EC’s tax-avoidance package differs from the
OECD’s recommendations.

May 6, 2016

Prop. Regs. Would Impose Reporting Requirements on Foreign-Owned Disregarded Entities

Foreign-owned disregarded entities, such as LLCs, would be required to report transactions with their owner and keep records under rules proposed by the Internal Revenue Service.

May 1, 2016

Notice 2015-79: New Anti-Inversion Guidance

IRS inversion guidance introduces new restrictions on corporate inversions and post-inversion restructuring transactions.

May 1, 2016

Water’s-Edge Election: Effectively Connected Income and the 20% Rule in California

This item discusses how foreign corporations that generate income from intangible assets are affected by the economic nexus rules as well as the water’s-edge rules.

May 1, 2016

Earnings Stripping: Effective Tax Strategy to Repatriate Earnings in a Global Economy

Earnings-stripping strategies can be an effective way to repatriate earnings at little or
no tax cost; however, taxpayers must be aware of the rules under Sec. 163(j).