Organisation for Economic Co-operation and Development guidance could offer cost savings to multinational companies, particularly small and compliant ones.
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International Tax
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.
Nonresident Alien Gamblers Get Similar Treatment as U.S. Gamblers
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.
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).
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
