The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
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International Tax
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.
Defining “Attributable to” Under Sec. 897(g)
The lack of regulatory and published guidance has created uncertainty in applying Sec. 897 to determine the amount of gain attributable to a USRPI.
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.
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.
