International Tax

Topics

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.

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.