To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income
tax return.
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International Tax
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).
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.
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.
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.
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.
IRS Finalizes Country-By-Country Reporting Regulations
The IRS issued final regulations implementing new country-by-country reporting requirements.
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.
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.
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.
Considerations on Whether to Check the Box for Foreign Subsidiaries
The decision affects both the timing and ultimate U.S. taxation of foreign income.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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