A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.
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International Tax
The proposed PTEP rules: Tax basis considerations under Sec. 961
Proposed regulations for previously taxed earning and profits of foreign corporations address a range of considerations for shareholder basis adjustments.
Using transfer pricing to blunt the effects of tariffs
Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on earnings.
Disregarded-payment-loss rules: How multinationals should prepare
New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.
Partnership reporting of contributions to foreign entities
Substantial penalties may be imposed if a taxpayer fails to report contributions to foreign entities.
Tax planning for inpatriates
Individuals relocating to the United States may face an array of income tax and information reporting issues.
Elections under the new Sec. 987 final regs.
Businesses with foreign branches receive new guidance on adjusting for currency exchange gain or loss.
FTR notification requirement for taxpayers under LB&I examination
A foreign tax redetermination may require taxpayers under Large Business and International Division examination to notify the IRS, which will redetermine the U.S. tax owed.
How Trump’s opposition to global tax deal may affect businesses
The Trump administration has rejected the OECD’s initiative to reform the taxation of multinational enterprises. Learn more about the executive action in this Q&A with an international tax expert.
Transfer pricing: The C-suite needs to be informed
CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain tax positions, and customs valuations.
Tax considerations for foreign investment in US private credit
Foreign investors should carefully analyze tax implications and strategies before investing in the growing U.S. market for nonbank credit.
On DRD, the IRS seeks to have its cake and eat it too
The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS Office of Chief Counsel held, contrary to the Service’s argument in a recent Tax Court case.
The CFC/PFIC overlap rule after aggregate treatment
Investors holding less than 10% of a controlled foreign corporation (CFC) are generally no longer shielded from double taxation under both the passive foreign investment company and CFC rules.
Treasury provides guidance on the interaction of DCLs with Pillar Two taxes
Proposed regulations would harmonize dual consolidated losses with the Organisation for Economic Co-operation and Development’s Global Anti-Base Erosion Model Rules.
IRS FAQ clarifies sunset of Notice 2010-46 credit forward framework
Frequently asked questions on Foreign Account Tax Compliance Act compliance now address a method for correcting overwithholding on dividends.
No Collection Due Process hearing for FBAR penalties
A hearing is available only for taxes imposed by Title 26, the Internal Revenue Code, as opposed to the taxpayers’ foreign bank account reporting penalties under U.S. Code Title 31, the Tax Court held.
New prop. regs. limit taxpayers’ foreign currency elections
The regulations would promote consistency with filing requirements for controlled foreign corporations and limit certain elections regarding foreign currency gains and losses.
CRFB leader: Tax policy may not be a Trump administration high priority
The head of the nonpartisan Committee for a Responsible Federal Budget told the AICPA & CIMA National Tax Conference that extending the Tax Cuts and Jobs Act would add $5 trillion to the national debt.
Sec. 245A dividends-received deduction allowed for Sec. 78 dividend
In Varian Medical Systems Inc., the Tax Court found the company eligible for the deduction for 2018 despite a disqualifying change in Sec. 78, due a mismatch between the change’s effective date versus the effective date of then-new Sec. 245A.
Implications of the Supreme Court’s Moore decision
The Moore decision could support other forms of recognition of undistributed earnings by entities to their shareholders or members, particularly in the international sphere, as well as new proposed taxes on other forms of wealth.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
