When a controlled foreign corporation (CFC) sells property used in its active business, any gain generally is not treated as subpart F income includible in its U.S. shareholders’ taxable income.
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International Tax
Final Regs. on Reporting Interest on Deposits Paid to Foreign Taxpayers
The IRS issued final regulations outlining the rules requiring U.S. financial institutions to report interest payments to certain nonresident alien individuals of $10 or more per year paid after 2012.
Temp. Regs. Issued on Obligations Arising From Certain Upfront Payments by CFCs
The IRS issued temporary regulations relating to the treatment of upfront payments made pursuant to certain notional principal contracts for U.S. federal income tax purposes.
IRS Releases New FAQs for Offshore Voluntary Disclosure Program, Announces Other Rules
The IRS released 55 questions and answers regarding its offshore voluntary disclosure program.
IRS Suspends Issuing ITINs Without Original Documentation
The IRS will no longer issue individual taxpayer identification numbers unless the applicants provide original documents, such as passports or birth certificates, or certified copies of those documents from the issuing agencies.
IRS Issues Regulations on “Expatriated Entities” Under Sec. 7874
The IRS issued final, temporary, and proposed regulations intended to prevent abusive corporate inversion transactions.
FATCA’s Withholding Requirements for Foreign Financial Institutions
FATCA imposes rigid new account identification, reporting, and tax withholding requirements on foreign financial institutions and other withholding agents.
Obligations Arising From Certain Upfront Payments Made by CFCs Are Not U.S. Property
The IRS issued temporary regulations relating to the treatment of upfront payments made pursuant to certain notional principal contracts for federal income tax purposes.
FBAR: Handle With Care
Failing to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), can result in severe civil and/or criminal penalties.
Foreign Limitations on Tax Loss Carryovers May Affect U.S. Foreign Tax Credits
Many foreign countries have recently made statutory changes to their tax loss carryover periods and limitations that may affect the U.S. accounting for income taxes of any U.S. company with foreign subsidiaries operating in jurisdictions where the limitations have been enacted.
Rules for Reporting Interest on Deposits Paid to Foreign Taxpayers Are Finalized
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.
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.
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.
