Seventh Circuit upheld a district court’s decision to spare Beanie Babies billionaire prison time for evading taxes by hiding assets in a Swiss bank account.
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International Tax
Foreign Tax Credit: When Is It Too Late to Change Your Mind?
The IRS has effectively made the 10-year window for switching between credit and deduction a one-way street that only allows a change from deduction to credit.
Constructive Presence Would Count Under Proposed Residency Rules
The IRS issued proposed regulations that, for purposes of establishing bona fide residency in a U.S. territory, would allow individuals additional days of “constructive presence” in the territories if certain conditions are met.
U.S. Tax Implications of Alimony Payments to U.S. Nonresidents
This item explains the tax implications for the payers and recipients of alimony from an international perspective.
Sec. 962 to the Rescue
International tax provisions, including the anti-deferral regime and mechanics of the foreign tax credit, can present significant and unique challenges to maintaining a tax-efficient structure.
Final Rules Define Substantial Business Activities Under Sec. 7874
The IRS issued final regulations to determine when an expanded affiliated group will be considered to have substantial business activities in a foreign country, which could allow a foreign corporation to escape application of the inversion rules.
Tax Treatment and Planning Strategies for Nonresident Individuals
This article provides an outline of the basic tax-compliance rules, as well as tax planning strategies, for nonresident aliens.
Basis Adjustments in CFC Stock Held by Partnerships for Subpart F Inclusions, PTI Distributions
Application of PTI rules to partnerships can be tricky, in part because domestic partnerships are treated as U.S. persons, but foreign partnerships are not. Therefore, a domestic partnership can be a U.S. shareholder of a CFC and entitled to a Sec. 961(a) basis adjustment for the CFC stock it owns, but a foreign partnership, even if owned by U.S. persons, is not so entitled.
Relief From Penalties for Late-Filed International Information Returns
Penalties apply for failure to report the information required under Secs. 6038 and 6038A by failing to timely file Form 5471, 5472, or 8865. There are two procedural paths for a taxpayer that files a late form.
Defining “Withholding Agent”: When “Everyone” Is Both Too Much and Not Enough
In the more than 100 years that U.S. withholding tax has been imposed on payments of U.S.-source income to foreign persons, the definition of a "withholding agent" has remained virtually unchanged.
IRS Proposes to Define Active Conduct of a Trade or Business Under PFIC Rules
Proposed regulations would clarify the circumstances under which investment income a foreign insurance company earned is derived in the active conduct of an insurance business for determining whether the income is passive income, and thus the extent to which the company’s assets are treated as passive assets in determining whether the company is a passive foreign investment company.
Indirect Taxes in India: Time for Reform?
This item provides an overview of the current indirect tax system in India and highlights changes proposed by a newly elected government, which, if adopted, would become effective in April 2016.
BEPS Country-by-Country Reporting: The Practical Impact for Corporate Tax Departments
The OECD’s Action Plan on Base Erosion and Profit Shifting included the highly anticipated final version of its recommended country-by-country reporting template.
Reports of the Double Irish’s Death Are Greatly Exaggerated
Ireland amended its statutes to provide that new companies incorporated in Ireland will be treated as Irish tax residents by default. However, a closer examination of this change and other untouched areas of Irish law illuminates another route by which companies may be able to achieve benefits similar to the Double Irish structure.
FATCA: A New World of Terminology and Compliance
FATCA introduced a new reporting and tax withholding regime, effective July 1, 2014, that is directed at both foreign financial institutions and nonfinancial foreign entities to prevent tax evasion by U.S. citizens and residents through use of offshore accounts.
IRS Intends to Amend Rules So Refunds Match Foreign Withholding Payments
The IRS proposed that taxpayers that are subject to withholding under Ch. 3 or 4 and that make claims for refunds or credits of the withheld tax be prevented from obtaining them where a withholding agent failed to deposit the required amounts.
Proposed PFIC Rules Would Define “Active Conduct” of an Insurance Business
Proposed regulations would clarify the circumstances under which investment income earned by a foreign insurance company is derived in the active conduct of an insurance business for purposes of determining whether the income is passive income.
Guiding Clients Through the Offshore Voluntary Disclosure Program
This item provides a synopsis of the steps and procedures involved in initiating and completing a successful voluntary disclosure through the OVDP.
FIRPTA Rules Impact U.S. Real Estate Transactions
Prospective purchasers should be aware of withholding tax obligations and tax reporting requirements under the Foreign Investment in Real Property Tax Act.
Selling Partnerships That Own CFCs: A Potential Trap for the Unwary
Should gain recognized on a sale of a partnership that owns CFC stock be treated as capital gain or ordinary income?
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.
