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.
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International Tax
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.
When Is a Foreign Tax Creditable Under Sec. 901?
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.
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.
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.
