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.
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Topics
International Tax
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.
Anti-Tax Avoidance Directives Issued by European Commission
The European Commission issued two proposed directives regarding international taxation.
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.
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.
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.
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.
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.
Final Rules Govern Sec. 6038D Reporting by Specified Domestic Entities
The IRS finalized proposed regulations issued in 2011 that require reporting of specified foreign financial assets by specified domestic entities on Form 8938, Statement of Specified Foreign Financial Assets.
Amended Rules Govern FIRPTA Dispositions After PATH Act
Provisions of the Protecting Americans From Tax Hikes Act of 2015 changed the tax treatment of dispositions of investments in real property by foreign taxpayers.
IRS Holds Its Ground in Substantial Business Activity Regulations
Despite IRS moves to curb corporate inversions, some multinational corporations still search for low-tax jurisdictions.
Regulations Clarify Partnership Allocations of Creditable Foreign Taxes
New rules released by the IRS are intended to improve an existing safe harbor for allocating creditable foreign taxes so that they are deemed to be in accordance with the partners’ interests in the partnership.
Foreign Corporation Earnings and Profits: Common Misconceptions and Pitfalls
This item provides an overview of E&P of foreign corporations and several common misconceptions that directly affect E&P.
New Rules Aimed at Further Curtailing Inversions
The IRS announced new rules rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
European Commission Issues Anti-Tax Avoidance Directives
Proposals include automatic exchange of the information gathered under new country-by-country reporting requirements.
Taxation of Outbound Transfers of Foreign Goodwill or Going Concern Value Under Secs. 367(a) and (d)
The regulations would eliminate the exception in the current temporary regulations for the transfer
of foreign goodwill and going concern value.
Recently Issued Regulations Will Increase Likelihood of Sec. 956 and Subpart F Income Inclusions
The regulations limit the application of the “active rents and royalties” exception to foreign
personal holding company income, expanding the instances in which a controlled foreign corporation will be treated as holding U.S. property.
Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules With Other Code Provisions
The regulations would clarify the application of the arm’s-length standard when multiple Code sections apply.
IRS Issues Updated Guidance on Requesting and Obtaining an APA
The IRS has issued updated guidance on requesting and obtaining an advance pricing agreement, modifying somewhat its proposed
revenue procedure published in Notice 2013-79.
Revised Procedures for Obtaining Assistance From U.S. Competent Authority, Including Discretionary Relief
The IRS published guidance on the process
of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
