International Tax

Topics

January 23, 2013

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.

January 18, 2013

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.

January 1, 2013

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.

January 1, 2013

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.

January 1, 2013

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.

December 1, 2012

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.

November 29, 2012

New ITIN Procedures Issued for 2013 Filing Season

The IRS promised issued new ITIN procedures for the 2013 filing season.

November 1, 2012

Treasury Releases FATCA Model Intergovernmental Agreement

The Treasury Department released its long-awaited model intergovernmental agreement to improve tax compliance and to implement FATCA.

November 1, 2012

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.

October 24, 2012

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.

October 4, 2012

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.

October 1, 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.

October 1, 2012

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).

October 1, 2012

U.S. LLCs for U.K. Tax Purposes

What are the global tax implications for LLC members who are not U.S. residents?

October 1, 2012

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.

September 1, 2012

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.

September 1, 2012

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.

September 1, 2012

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.

September 1, 2012

New FAQs and Rules for Offshore Voluntary Disclosure Program

The IRS released 55 questions and answers updated for the 2012 offshore voluntary disclosure program.

August 9, 2012

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.