The lack of regulatory and published guidance has created uncertainty in applying Sec. 897 to determine the amount of gain attributable to a USRPI.
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International Tax
Interplay of Withholding Obligations on Partnership’s Disposition of U.S. Real Property
It is important to be mindful of the applicability and interplay of the various withholding obligations that may arise when foreign persons make direct or indirect investments in USRPIs.
Modifications to EU VAT Sourcing Rules
This item discusses the basic principles of the EU VAT and the sourcing rules for sales of telecommunications, broadcasting, and electronically supplied services to businesses and individuals.
Dealing With the Secondary U.S. Tax Consequences of Transfer-Pricing Adjustments
This article explains how a transfer-pricing adjustment triggers secondary financial consequences in a multinational group.
Asset Transfers to Foreign Corporations
The IRS issued final, temporary, and proposed regulations governing outbound asset transfers under Sec. 361.
Switzerland Proposes Allowing Banks to Resolve U.S. Tax Evasion Cases
Switzerland would allow its banks to disclose data about account holders to the Justice Department under a bill that will be introduced in the Swiss parliament.
Foreign Corporations Investing in Partnerships: Common Branch Profits Tax Issues
Highlights of the tax compliance challenges that often arise as a result of U.S. branch profits tax exposure.
Sec. 901(m): Potential Trap for Partnership Transactions
New Sec. 901(m) limits the creditability of foreign taxes in certain acquisition transactions where a taxpayer receives a basis step-up for U.S. tax purposes but no corresponding basis step-up for foreign tax purposes.
Switzerland Agrees to FATCA Reporting Rules
The Treasury Department announced that the United States and Switzerland have signed a bilateral agreement to implement provisions of FATCA.
Widow Avoids Jail Time and Probation in Sentencing for Offshore Account Tax Evasion
A taxpayer was sentenced to one year of probation in federal district court, following her guilty plea to charges of tax evasion, but the judge almost immediately revoked that sentence.
International Tax Issues for Newly Multinational Corporations: A Due-Diligence Perspective
A taxpayer that ventures into international business by acquiring a multinational target may encounter a number of tax issues that could result in significant unanticipated tax liabilities.
U.S. Withholding Tax Requirements on Payments to Nonresidents and Foreign Entities
This item provides an overview of the types of income subject to U.S. withholding tax and related U.S. information reporting requirements.
Specified Foreign Financial Asset Reporting Postponed
The IRS announced that it is postponing for at least one year the requirement that domestic entities report interests in specified foreign financial assets.
FATCA Final Regulations Issued
The IRS issued final regulations providing rules on information reporting by foreign financial institutions (FFIs) and withholding on certain payments to FFIs and other foreign entities.
Tax Court Weighs In on STARS Transaction
The Tax Court held that a bank was not entitled to the tax benefits generated by a STARS transaction because the transaction lacked economic substance.
Cross-Border Taxation
Once the exclusive province of large accounting and law firms, now even the smallest firms must master cross-border tax issues.
U.S. and Switzerland Sign FATCA Agreement
The United States and Switzerland have signed a bilateral agreement to implement provisions of FATCA.
Changes to Rules on Failure to File Gain Recognition Agreements Proposed
The IRS issued proposed regulations to update the rules that apply to U.S. taxpayers that fail to file gain recognition agreements when they transfer certain property to foreign corporations in nonrecognition transactions
Sec. 6038D Reporting of Specified Foreign Financial Assets Postponed for One Year
The IRS announced that it is postponing for at least one year the requirement that domestic entities report interests in specified foreign financial assets.
FATCA Final Regulations Cover All the Bases
The IRS issued final regulations providing rules on information reporting by foreign financial institutions (FFIs) and withholding on certain payments to FFIs and other foreign entities.
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.
