Should gain recognized on a sale of a partnership that owns CFC stock be treated as capital gain or ordinary income?
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International Tax
Taxpayer Was a Bona Fide Resident of U.S. Virgin Islands
Taxpayer who had filed tax returns with the U.S. VIBIR was a bona fide resident of the U.S. Virgin Islands, and the statute of limitation on assessment had expired on the U.S. returns.
Offshore Disclosure Program a Success, Will Remain Open
The IRS stated that it intends to keep its Offshore Voluntary Disclosure Program (OVDP) open until it announces otherwise.
Form 5472 Regulations Are Finalized Prohibiting Filing Form Separately
Final regulations issued by the IRS remove the provision allowing Form 5472 to be timely filed separately from the corporation’s tax return if that return is filed late.
Final Regulations Address Gain Recognition Agreements and Other Cross-Border Transfer Reporting
Final regulations revise the reporting rules applicable to stock and property transfers under Secs. 367 and 6038B, including Sec. 367(a) gain recognition agreements.
OECD’s Draft Proposal on Treaty Shopping, Treaty Abuse Situations
The OECD recently issued a report that includes proposed changes to the Model Tax Convention, which are intended to prevent treaty abuse, and commentary on the changes.
IRS Opens Secure Portal for FATCA Reporting
Financial institutions and tax administrators that have an obligation under U.S. tax law to report account information to the IRS now have a secure online site where they can transmit that information, the IRS announced.
Regulations on Reporting Specified Foreign Financial Assets Are Finalized
Individuals who are required to report interests in foreign financial assets to the IRS got guidance on the process in the form of final regulations. The regulations finalize temporary regulations issued in 2011, with some changes.
Final Rules Govern Foreign Tax Credit Splitter Arrangements
The IRS issued regulations that prohibit taxpayers from taking a foreign tax into account for federal foreign tax credit purposes before the tax year in which the taxpayer takes the related income into account.
IRS Offers New Options for Taxpayers Who Failed to File International Information Returns
This item is an overview of the ways a taxpayer can deal with the failure to file required international information returns.
Final Regulations Issued on Relief From Failure to File Gain Recognition Agreements
The IRS finalized proposed regulations to update the rules that apply to U.S. taxpayers that fail to file gain recognition agreements (GRAs) when they transfer certain property to foreign corporations in nonrecognition transactions (T.D. 9704). The rules change the standards under which transferors are required to recognize gain on the transfer of stock or securities.
Exchange of Tax Information Should Be Automatic, G-20 Leaders Say
G-20 leaders committed their countries to automatically exchanging information with one another by the end of 2018.
Offshore Voluntary Disclosure Program to Remain Open Indefinitely
The IRS stated that it intends to keep its Offshore Voluntary Disclosure Program open until it announces otherwise.
U.S. Government Opens Secure Portal for FATCA Reporting
Financial institutions and tax administrators that have an obligation under U.S. tax law to report account information to the U.S. government now have a secure online site where they can transmit that information.
Procedures for Withholding Foreign Partnerships and Withholding Foreign Trusts Coordinated With FATCA
The IRS issued updated procedures in Rev. Proc. 2014-47 for "withholding foreign partnerships" and "withholding foreign trusts" that elect to assume certain U.S. withholding tax responsibilities.
IRS Allows Sec. 1298(f) Filing Exemption for Certain Holders of Marked-to-Market PFIC Stock
The IRS announced that it will amend the Sec. 1298(f) regulations to create an exception from its filing requirements for U.S. persons holding passive foreign investment company (PFIC) stock that is marked to market under Sec. 475 or another Code section other than Sec. 1296.
IRS Updates Streamlined Offshore Compliance Procedures
The IRS updated its streamlined offshore compliance procedures and issued new frequently asked questions (FAQs) about the procedures.
Regulations Tightening Form 5472 Filing Requirements Are Finalized
Final regulations remove the provision allowing Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, to be timely filed separately from the corporation’s tax return if that return is filed late.
Final Rules Govern Reporting of Specified Foreign Financial Assets
Individuals who are required to report interests in foreign financial assets to the IRS got guidance on the process in the form of final regulations.
Complex Foreign Reporting Rules Make Compliance Difficult for Individual Taxpayers
Certain foreign reporting requirements may not be well-known by individual taxpayers; therefore, these reporting requirements may be overlooked, causing those individuals to bear heavy penalties for noncompliance.
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.
