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.
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International Tax
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.
Notice 2015-79: New Anti-Inversion Guidance
IRS inversion guidance introduces new restrictions on corporate inversions and post-inversion restructuring transactions.
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.
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).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
