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).
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International Tax
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.
IC-DISC Offers Tax Advantages for Closely Held Export Companies
For a closely held U.S. company engaged in export sales, an IC-DISC offers opportunities to both reduce the amount of revenue subject to the ordinary income tax rate and provide financial compensation to employees, shareholders, or other stakeholders.
IRS Issues Regs. on Sec. 7874 Expatriated Entities
The IRS issued temporary regulations governing whether a foreign corporation has “substantial business activities” in a foreign country compared to the total business activities of the expanded affiliated group
When Becoming a U.S. Resident, Beware of PFIC Rules
As the workforce becomes more mobile, many non-U.S. citizens who become U.S. residents for work reasons have to deal with not only cultural adjustments but also the unanticipated workings of the PFIC tax regime.
Treasury Releases Model Intergovernmental Agreement for FATCA
Treasury released a model intergovernmental agreement designed to implement the information-reporting and withholding-tax provisions in FATCA.
Increased Focus on International Activities of Tax-Exempt Organizations
Many tax-exempt entities participate in the global economy by engaging in charitable or other exempt activities overseas and making foreign financial investments; These activities have drawn attention from the IRS as they examine the flow of tax-exempt funds around the world.
Employment Tax Liabilities of Foreign Entities
A number of technical questions are involved in determining status as an employer for federal employment tax purposes when a foreign business sends individuals to work in the United States.
FIRPTA Notice Requirements for Property Acquired in Foreclosure Sale
Parties involved in the disposition of a U.S. real property interest as the result of a repossession of or foreclosure on the property need to be aware of their ) withholding requirements, as well as the availability of alternative withholding and notice requirements for foreclosure dispositions.
Potential Pitfalls in PFIC Reporting
PFIC investors should be aware of new PFIC reporting requirements and should be alert to developments that may affect them.
Homeland Security May Contact U.S. Persons Living Abroad Who Owe Back Taxes
The IRS has established procedures to facilitate tax collection from taxpayers who live outside the United States, including submitting identifying taxpayer information to a database maintained by the Department of Homeland Security.
Issues Facing Partnerships Under FIRPTA
This item identifies several issues taxpayers should be aware of to the extent they invest in partnership structures that hold U.S. real property interests.
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.
