The IRS issued final regulations requiring U.S. financial institutions to report interest payments to certain nonresident alien individuals of $10 or more per year.
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International Tax
FATCA Adds Layer of Complexity, Penalty Exposure to Offshore Asset Reporting
This item highlights the provisions of FATCA that are most likely to affect U.S. tax practitioners and their clients—the taxpayer reporting provisions of new Sec. 6038D.
Estate Planning for International Clients
It is essential for clients with multiple citizenship or residency to understand that the timing and manner of cross-border wealth transfers fundamentally affect their ability to minimize tax burdens.
Potential Pitfall Associated with Reorganizations Involving Chinese Subsidiaries
When a U.S. company wants to reorganize a worldwide structure that includes Chinese entities, tax issues should be carefully considered to avoid any unforeseen Chinese tax liability.
FATCA Prop. Regs.
The IRS on issued proposed regulations providing rules on information reporting by foreign financial institutions (FFIs) and withholding on certain payments to FFIs and other foreign entities.
Regs. on Foreign Tax Credit Splitter Arrangements
The IRS issued regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and on the application of the “anti-splitter” rules of Sec. 909.
IRS and OECD Separately Address Transfer Pricing Issues
The IRS announced a reorganization of its advance pricing agreement (APA), mutual agreement, and competent authority programs into one new program.
U.S. Sandwich Structures in the International Inbound Context
When a foreign multinational operates in the United States through a U.S. group that has underlying foreign operations—a “U.S. sandwich structure”—repatriating the U.S. group’s foreign earnings often results in tax inefficiencies.
Third Offshore Voluntary Disclosure Program Launched
The IRS announced it was starting a third offshore voluntary disclosure initiative (OVDI) designed to help people with unreported offshore accounts get current with their taxes in the United States.
FinCEN Postpones Mandatory FBAR E-Filing
FinCEN announced that it is postponing until July 1, 2013, its requirement that FBARs be filed electronically.
Supreme Court: Filing a False Tax Return Can Lead to Deportation
The Supreme Court held that a conviction under Sec. 7206 for willfully filing a false tax return (or for aiding and abetting filing a false tax return) is an aggravated felony that can result in deportation.
FinCEN Once Again Extends FBAR Filing Deadline for Certain Financial Professionals
FinCEN announced a further extension of the deadline for filing FBARs, to June 30, 2013, for a small group of financial professionals
Foreign Tax Credit Regs. on Splitter Arrangements, Determining Who Is Liable for Foreign Tax
The IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and temporary regulations on the application of the “anti-splitter” rules of Sec. 909.
Proposed FATCA Regs. Take Comprehensive Approach
The IRS issued proposed regulations providing rules on information reporting by foreign financial institutions (FFIs) and withholding on certain payments to FFIs and other foreign entities.
Specified Foreign Financial Assets Reporting Regs. Issued
The IRS issued temporary and proposed regulations on the requirement that certain foreign financial assets be reported to the IRS for tax years beginning after March 18, 2010.
The Dual Consolidated Loss Quandary
The rules and regulations pertaining to dual consolidated losses are very complex; practitioners should always be diligent and aware of possible DCL scenarios.
Statutory Definition of Specified Notional Principal Contract Extended Through 2012
The IRS issued temporary and proposed regulations on dividend equivalents for purposes of Sec. 871(m).
IRS Announces Third Offshore Voluntary Disclosure Program
The IRS announced it is starting its third program designed to help people hiding offshore accounts get current with their taxes in the United States.
New Reporting for Specified Foreign Financial Assets
Effective for tax years starting after March 18, 2010, new Sec. 6038D requires individual taxpayers to report any interest in “specified foreign financial assets” if the value of these assets in aggregate exceeds an applicable threshold amount.
Foreign Financial Asset Reporting Form Finalized
The IRS released the final version of Form 8938, Statement of Specified Foreign Financial Assets, and its instructions.
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.
