International Tax

Topics

May 1, 2016

Specified Domestic Entities Must Now Report Under Sec. 6038D

The regulations require specified domestic entities to report specified foreign financial assets in which they have interests.

April 27, 2016

Court Dismisses FATCA Challenges

In a case challenging the foreign reporting requirements under FATCA and the Report of Foreign Bank and Financial Accounts, a number of plaintiffs, including Sen. Rand Paul of Kentucky, had their claims dismissed by a federal court.

April 12, 2016

FATCA Deemed Stock Distribution Reporting Rules Proposed

The IRS issued proposed regulations providing guidance that clarifies the amount, timing, and reporting of deemed distributions of stock and rights to acquire stock.

April 5, 2016

IRS’s Inversion Rules Include Earnings-Stripping Provisions

These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.

April 4, 2016

Panama Papers Leak Provides Road Map for Tax Investigations

Tax authorities in various countries announced the launch of investigations after 11.5 million documents were leaked from a Panamanian law firm that specializes in setting up offshore entities.

April 1, 2016

Foreign Oil and Gas Tax Credits Subject to Separate Credit Limitations

A recharacterization of royalties as income tax in some countries results in a high rate of foreign tax imposed on foreign oil and gas income that can be creditable against the U.S. tax.

April 1, 2016

Streamlined Filing Procedures for Disclosing Foreign Assets and Income

Qualifying taxpayers who failed to report foreign-source income and can prove their conduct was not “willful” could enjoy significantly reduced penalties.

April 1, 2016

Rules for Partnership Allocations of Creditable Foreign Taxes Are Amended

Temporary regulations issued by the IRS amend an existing safe harbor that is used for determining whether allocations of CFTEs are deemed to be in accordance with the partners’ interests in the partnership.

April 1, 2016

Tax Planning for High-Net-Worth Individuals Immigrating to the United States

Foreign high-net-worth individuals immigrating to the United States should seek advice to minimize exposure to the U.S. income, gift, and estate tax system.

April 1, 2016

Anti-Tax Avoidance Directives Issued by European Commission

The European Commission issued two proposed directives regarding international taxation.

April 1, 2016

German Who Gave Up U.S. Residency Liable for Exit Tax

A taxpayer had expatriated in November 2010 when he surrendered his legal permanent resident status and therefore was subject
to Sec. 877A.

March 1, 2016

Tax Planning Insights for Foreign Work Assignments

This column provides a basic overview of what one would want to know when advising clients prior to foreign work assignments.

March 1, 2016

The Common Reporting Standard: Impact on Financial Services Institutions

The CRS requires financial institutions resident in participating jurisdictions to implement due-diligence procedures, to document and identify reportable accounts, and to establish a wide-ranging reporting process.

March 1, 2016

Exceptions to Branch Profits Tax Available to Foreign Corporations With U.S. Tax Compliance Obligations

This item addresses certain limited exceptions to branch profits tax.

March 1, 2016

Country-by-Country Reporting Rules Are Issued in Proposed Form

To conform U.S. procedures with the BEPS project to prevent multinational companies from shifting profits to low- or no-tax jurisdictions, the IRS issued proposed rules
governing reporting by any U.S. person that is the “ultimate parent entity” of a multinational enterprise.

February 22, 2016