The D.C. Circuit held that nonresident aliens should measure their gambling gains and losses under the “per-session” approach, the same method that U.S. citizens follow, instead of a "per-bet" approach.
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International Tax
CFC’s Software Leasing Income Determined to Be Foreign Personal Holding Company Income
The IRS addressed whether rental income from software leasing to third parties outside the country of a controlled foreign corporation is foreign personal holding company income.
American Depositary Receipts Are U.S.-Source Income Subject to Withholding
The IRS addressed the character and source of payments by a domestic depositary institution made to, or on behalf of, a foreign corporation in consideration for a grant of the exclusive right to offer ADRs, and whether those payments are subject to withholding under Sec. 1442.
Regs. Curb Artificially Generated Foreign Tax Credits
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
Guidance Issued for FFIs with FATCA Agreements
The IRS issued its latest guidance in preparation for the implementation of the FATCA reporting and withholding requirements.
Foreign Account Tax Compliance Act Update
The U.S. initiative in combating tax evasion and improving global compliance has become a worldwide initiative, since it is viewed as a win-win for most countries.
FATCA Withholding on Payments to Nonfinancial Foreign Entities: A Broad New Requirement
Beginning July 1, 2014, U.S. taxpayers that have nothing to do with financial services will be required to collect, analyze, document, and report information regarding payments to both foreign financial institutions and nonfinancial foreign entities.
Gambling Gains for Nonresidents Now the Same as for U.S. Residents
A decision by the D.C. Circuit puts nonresident aliens’ gambling gains on a closer footing to those of U.S. residents.
IRS Postpones FATCA Deadlines for Six Months, Posts Draft FATCA Report Form
The IRS announced a six-month delay in some of the deadlines for implementing FATCA.
Foreign Citizen Denied Refund of Erroneously Withheld Taxes
The Federal Circuit upheld the IRS’s denial of a request for refund of erroneously withheld taxes because the taxpayer filed his claim for a refund well after the end of the three-year lookback period in Sec. 6511(b)(2)(A).
Final Regulations Attack Artificially Generated Foreign Tax Credits
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
Local Country Tax Incentives and the Foreign Tax Credit
U.S. multinationals operating in foreign jurisdictions via subsidiary corporations may be shortchanging themselves when they account for the effect of local incentives on available foreign tax credits in the United States.
FATCA Regulations’ Effective Date Approaching Quickly
As of July 1, 2014, withholding agents must have processes in place to determine and document the FATCA status of their payees before payment is made.
Online FATCA Registration System Launched
The IRS on Monday announced the launch of an online system that foreign financial institutions can use to register with the agency to meet their obligations under FATCA.
IRS Issues Draft FATCA Report Form
The IRS released a draft Form 8966, FATCA Report, which will be used by foreign financial institutions and withholding agents to comply with their FATCA reporting and withholding requirements.
Cross-Border Pension Rollover Creates U.S. Taxable Income
As the global workforce becomes increasingly mobile, more and more workers must wade through the intricacies of cross-border taxation.
Taxpayers Receive Notice That IRS Is Resolving Form 3520 Processing Issues
The IRS plans to send out letters to taxpayers who filed Form 3520 or Form 3520-A as it attempts to close out outstanding inquiries/correspondence involving Form 3520 prior processing issues.
FATCA Deadlines Are Postponed for Six Months
The IRS said it was delaying for six months some of the deadlines for implementing FATCA.
Totalization Agreements: Taking Exception to Social Security
A totalization agreement is intended to eliminate dual social taxation and to provide additional benefit protection for workers who have worked in both the United States and another country.
Foreign Branch Incorporation: Interaction of OFL, Branch Loss Recapture Rules
This item discusses the interaction between two recapture rules—OFL recapture and branch loss recapture—triggered by a branch incorporation.
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.
