Brazil has what may be the most complex indirect tax system in the world. This item provides an overview of the four major Brazilian indirect taxes that foreign business investors may encounter, including their scope, sourcing, base, rate, and recoverability.
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International Tax
IRS Announces Two-Year FATCA Enforcement Transition Period
Foreign financial institutions that make a good-faith effort to comply with the requirements of FATCA will benefit from lighter enforcement during 2014 and 2015.
FBAR and FATCA Compliance in the Age of Digital Currencies
Recent guidance and the popularity of new digital currencies raise questions about FBAR and FATCA reporting requirements.
A 21st Century PFIC Regime: Must All Working Capital Be Passive?
Draconian penalties of the PFIC rules may risk pushing U.S. investors toward missing the proverbial “information age” boat.
Changes for Foreign Financial Account Reporting
A new form has sections for including the reason for a late filing and the preparer information and must be electronically filed.
Foreign Corporations: Procedures and Pitfalls in Adopting and Changing Methods of Accounting for Purposes of Determining E&P
This item provides a high-level discussion of the general timing for certain foreign corporations’ adoption of methods of accounting for purposes of determining E&P, the procedural rules regarding how such foreign corporations change their method of accounting, and the importance of understanding when and how a method is adopted in light of the increased limitations such foreign corporations may face in changing methods.
Americans Living Abroad and the Net Investment Income Tax
This article describes how the net investment income tax may affect Americans living abroad.
Eight Countries Sign FATCA Agreements
The United States has signed eight more bilateral agreements to implement the reporting and withholding provisions of the Foreign Account Tax Compliance Act.
Income Derived Through Fiscally Transparent Entities: Practical Issues and Unintended Consequences
This discussion summarizes the general approach adopted by regulations and highlights practical difficulties encountered when determining whether a foreign company is entitled to treaty benefits when investing in the United States through an entity that may be fiscally transparent under the laws of one or more jurisdictions.
Final FATCA Rules Are Issued
The IRS released a large package of regulations needed to implement the Foreign Account Tax Compliance Act.
Transfer-Pricing Documentation: Possible Relief Ahead for Small Multinational Companies
Organisation for Economic Co-operation and Development guidance could offer cost savings to multinational companies, particularly small and compliant ones.
Swiss Court Stops Handover of Tax Information to United States
A Swiss court has prevented the handover of information on U.S. account holders to the IRS by the Julius Baer Group Ltd.
International Joint Audits: Is Two Better Than One?
In December 2011, the IRS announced its plans to implement a program, advanced by the Organisation for Economic Co-operation and Development’s (OECD’s) Forum on Tax Administration (FTA), to “jointly” audit multinational taxpayers with tax administrations from around the world, but always on the basis of a tax treaty between them.
The Creditability of Foreign Taxes: Form vs. Substance
The U.S. Supreme Court’s recent decision in PPL Corp is a significant development in determining which foreign taxes are creditable against U.S. income tax. This article examines the implications of the Supreme Court’s PPL decision, arguing that the Court’s decision highlights the flaws in the regulations many tax experts have previously identified.
FATCA Guidance Issued for Foreign Financial Institutions
The IRS has issued more guidance in preparation for the implementation of the Foreign Account Tax Compliance Act reporting and withholding requirements. The guidance applies to foreign financial institutions entering into an FFI agreement with the IRS under Sec. 1471 or to FFIs or branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement.
Withholding Rules for U.S. Citizens and Resident Aliens Working for a U.S. Employer in a Foreign Country
For income tax withholding purposes, the wages of U.S. citizens and resident aliens include all remuneration for services performed as an employee for an employer, regardless of whether the services are performed in the United States.
Final Regs. Determine Amount of Tax Paid for Purposes of the Foreign Tax Credit
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
Six More Countries Sign FATCA Agreements with U.S.
The Treasury Department announced that the United States has signed six more bilateral agreements to implement the reporting and withholding provisions of FATCA.
FBAR Reporting Considerations
The National Taxpayer Advocate has estimated that 5 million to 7 million Americans live abroad and many more living in the United States may have foreign accounts. That presents both an opportunity and a challenge.
United States and France Sign FATCA Agreement
The Treasury Department announced on Thursday that the United States and France have signed a bilateral agreement requiring French banks to report to the French government information about their U.S. account holders.
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.
