Leaders of the G-20 major economies endorsed the OECD’s global standard for automatic exchange of tax information at the G-20 summit in Brisbane, Australia.
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International Tax
IRS Can Notify a Withholding Agent of Foreign Person’s Incorrect Claim of Withholding Exemption
IRS concluded it has authority to notify a withholding agent that a foreign person’s claim of withholding tax exemption with respect to its income effectively connected with a U.S. trade or business is invalid.
Changes Made to IRS Streamlined Offshore Compliance Procedures
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program.
Certain FATCA Deadlines Are Postponed
The IRS announced its intention to modify the effective dates of the FATCA standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee and other rules.
Navigating the Net Investment Income Tax: Key Issues for Investment Funds and Their Partners
This item summarizes the aspects of the net investment income tax that are most relevant to hedge fund investors and general partners.
Keeping Up With Increasingly Mobile Clients: Navigating U.S. Tax Reporting for U.S. Persons With Ties to Foreign Trusts
Despite the significant efforts of tax advisers to ensure their U.S. clients understand and comply with required tax and information-reporting forms on U.S. trust relationships, all too often transactions go unreported, even though penalties in these cases can be quite severe.
Tax Advantages for U.S. Traders of Securities and Commodities Relocating to Puerto Rico
This article discusses opportunities for traders in securities and commodities to dramatically decrease the U.S. federal income tax they owe on trading gains by relocating to Puerto Rico.
PFIC Reporting Rules Do Not Apply to Certain Marked-to-Market Stock
The IRS announced that it will amend the regulations governing the reporting requirements for U.S. persons who hold stock in passive foreign investment companies.
IRS Provides FATCA Transition Relief for 2014 and 2015, Releases FFI Search Tool
Transition relief from enforcement may help withholding agents, foreign financial institutions, and other entities that have responsibilities under the the Foreign Account Tax Compliance Act.
Unused ITINs to Expire Under New IRS Policy
Under a new IRS policy, individual taxpayer identification numbers that are not being used will expire after five years.
Canadians’ Immigration to the U.S.: Taxes Coming and Going If Not Planned Properly
Canadians looking to immigrate to the United States must consider a number of tax issues. Despite similarities in the countries’ taxing systems, some significant differences must be properly planned for to avoid paying significantly higher cumulative taxes. This item focuses on a couple of the major differences that need to be considered before emigrating from Canada.
Form 5472 Filing Requirements to Become More Stringent
The IRS issued final and proposed regulations amending the rules for filing Form 5472.
New Rules on Covered Asset Acquisitions Will Shut Down Transactions to Avoid Sec. 901(m)
The IRS will issue regulations to prevent taxpayers from misapplying the statutory disposition rule in cases where the gain or loss from the disposition of the relevant foreign asset is recognized for U.S. income tax purposes but not for foreign income tax purposes.
Country-by-Country Reporting: Challenges and Considerations
Multinational enterprises should assess the potential challenges that country-by-country reporting could present for their organizations so they can adapt quickly to any future reporting obligations.
Sec. 956 and Subpart F Inclusions, Actual Distributions, and Previously Taxed Income
Previously taxed income rules were designed to prevent double taxation of a controlled foreign corporation’s earnings. Keeping track of a foreign corporation’s earings and profits under the rules can be complicated.
Understanding Your Clients’ FBAR Filing Obligations and Getting Them in Compliance
This item highlights two nuances of the scope of the FBAR reporting requirements that commonly result in filing missteps. For those who are delinquent, this item offers guidance on potential relief from penalties in accordance with applicable IRS procedures.
Filing Protective Claims Following Redetermination of Foreign Tax Liability
U.S. multinationals that have undergone a tax audit in a foreign jurisdiction resulting in additional foreign tax liability may be able to file an amended U.S. return with the IRS to claim a credit for foreign taxes paid. A special 10-year period of limitation applies to refunds resulting from these claims.
Two-Year FATCA Enforcement Transition Period Introduced
Foreign financial institutions that make a good-faith effort to comply with the requirements of the Foreign Account Tax Compliance Act will benefit from lighter enforcement during 2014 and 2015, the IRS announced. The IRS is treating those years as a “transition period” for the implementation of FATCA by withholding agents, foreign financial institutions, and other entities with FATCA reporting and withholding responsibilities.
New Streamlined Procedures and Changes to the Offshore Voluntary Disclosure Program Are Announced
The IRS announced changes to its streamlined filing compliance procedures and its Offshore Voluntary Disclosure Program designed to make it easier for taxpayers to comply with their obligations to report offshore assets and accounts.
Regs. Tighten Form 5472 Filing Requirements
The IRS is amending the rules for filing Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.
TAX PRACTICE MANAGEMENT
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