The Supreme Court has granted certiorari in a Third Circuit case to resolve a circuit split and to answer the question of when a foreign tax is creditable under Sec. 901.
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International Tax
FATCA Prop. Regs. Amended to Extend Various Deadlines
The IRS is delaying various FATCA-related deadlines because it has received feedback that complying with the original deadlines and other requirements is proving to be impractical for some taxpayers.
Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part II)
This two-part article explains the computations, payment, and reporting requirements for U.S. trust and estate distributions to foreign beneficiaries.
Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part I)
This article explains the procedures and tax compliance issues that fiduciaries face before domestic trust or estate distributions are paid or allocated to foreign beneficiaries.
New ITIN Procedures Issued for 2013 Filing Season
The IRS promised issued new ITIN procedures for the 2013 filing season.
Treasury Releases FATCA Model Intergovernmental Agreement
The Treasury Department released its long-awaited model intergovernmental agreement to improve tax compliance and to implement FATCA.
Advising Nonresidents and Recent U.S. Residents on Estate Tax Issues
Understanding the intricacies of residency and domicile is necessary to understand what will be included in a decedent’s estate for U.S. estate tax purposes.
FATCA Prop. Regs. Amended to Extend Various Deadlines
The IRS is delaying various FATCA-related deadlines because it has received feedback that complying with the original deadlines is difficult for some taxpayers.
IRS Issues Interim ITIN Procedures for 2011 Tax Returns on Extension
The IRS has posted special instructions for certifying acceptance agents to use in certifying identification documents for 2011 tax year filers who are filing on extension—returns that are due by Oct. 15, 2012.
QEF Elections Under PFIC Rules
In enacting the PFIC rules in 1986, Congress created a complex and punitive tax regime for certain passive foreign investments that continues to plague U.S. taxpayers and their tax advisers.
Potential U.S. Tax Consequences of Using Foreign Sales or Manufacturing Branches
The IRS late last year released final regulations on the rules for foreign base company sales income (FBCSI) under Sec. 954(a)(2) and Regs. Sec. 1.954-3(b).
U.S. LLCs for U.K. Tax Purposes
What are the global tax implications for LLC members who are not U.S. residents?
Model Intergovernmental FATCA Agreements Released; Draft Form Posted
The Treasury Department released a model intergovernmental agreement designed to implement the information-reporting and withholding-tax provisions of FATCA.
Guidance on Foreign Tax Credit Splitter Transactions
Treasury published temporary regulations to provide guidance on the Sec. 909 foreign tax credit splitter event provisions that were enacted in August 2010.
New Foreign Asset Reporting Rules
Practitioners need to be aware of the new requirements for reporting foreign assets and income and confirm that clients are complying.
Corporate Financing Companies: Treatment of Losses
Financial blocker entities are used as a mechanism to prevent funds from potentially being engaged in a U.S. trade or business.
New FAQs and Rules for Offshore Voluntary Disclosure Program
The IRS released 55 questions and answers updated for the 2012 offshore voluntary disclosure program.
TIGTA: IRS Encourages Employees to Ignore ITIN Fraud
TIGTA confirmed allegations from IRS employees that their supervisors were urging them to ignore potential fraud in a program that reviews and verifies applications for ITINs.
R&D Tax Incentives Around the World
With the R&D credit in limbo, now is the time to reevaluate the entire system by looking at other countries’ R&D tax incentives.
Potential Tax Changes Await Investors in 2013
Depending on political developments, taxpayers could face higher taxes on investment income in 2013, including a new Medicare tax on net investment income and the sunset of lower rates for capital gains and qualified dividends.
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.
