The IRS announced it had postponed the deadline for its 2011 Offshore Voluntary Disclosure Initiative (OVDI). The new due date for requests is September 9, 2011.
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International Tax
When Is a U.S. LLC a Partnership for U.S. and U.K. Tax Purposes?
U.S. LLCs have become the preferred business entity in many situations because their members get both legal liability protection while being taxed in the United States as a partnership. This item examines how profits and losses of a U.S. LLC will be taxed on a U.K. resident’s U.K. tax return.
Delinquent U.S. Foreign Information Returns: Is Filing Under the 2011 OVDI Appropriate?
This item explains the process by which taxpayers may take advantage of an opportunity to avoid a substantial portion of the penalties that would otherwise be due on previously unreported offshore accounts, entities, and income.
IRS and FinCEN Extend FBAR Deadlines for Certain Filers
The IRS has further extended the deadline for certain persons to file an FBAR form for 2009 and earlier years. U.S. persons with a financial interest in, or signature authority over, any financial accounts in a foreign country must file an FBAR if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year.
IRS Removes Form 5472 Duplicate Filing Requirement
The IRS has issued temporary and proposed regulations to remove the duplicate filing requirement for Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.
FinCEN Creates FBAR E-Filing System
FinCEN announced that it has developed an electronic filing system for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).
Phased Implementation of FATCA Requirements Announced
The IRS announced plans to phase in the requirements of the Foreign Account Tax Compliance Act (FATCA).
Penalty Relief for Delinquent FBARs and Forms 5471 Ends August 31
The IRS has provided penalty relief in guidance related to its latest offshore voluntary disclosure initiative. The focus of this item is on who qualifies for penalty relief and procedures for obtaining this relief.
Application of CFC Lookthrough Rule to Payments Made by a Partnership to Its CFC Partner
This item examines the controlled foreign corporation (CFC) lookthrough rule.
IRS Matching Program for Forms 8023 and 8883 May Result in Invalid Sec. 338 Election
The IRS recently launched a program to match the filing of Form 8023, Elections Under Section 338 for Corporations Making Qualified Stock Purchases, by a foreign purchasing corporation acquiring a foreign target, with Form 8883, Asset Allocation Statement Under Section 338, to report the effect of the Sec. 338 election.
Taxing Intellectual Property Transfers
Outbound transfers of intellectual property can raise difficult tax issues for U.S. persons.
FIRPTA and the Return of Capital Distributions
FIRPTA is quite complex and filled with traps for the unwary, especially in the area of return of capital distributions.
IRS Suspends Foreign Asset, Passive Foreign Investment Company Information Reporting Rules
The IRS announced that it is suspending the information reporting requirements for certain individuals with foreign assets and shareholders of passive foreign investment companies (PFICs) under Secs. 6038D and 1298(f) (Notice 2011-55)
IRS Further Extends Deadline for Certain 2009 and Earlier FBARs
The IRS has further extended the deadline for certain persons to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), for 2009 and earlier years (IRS Notice 2011-54). The new filing deadline is November 1, 2011. The extension applies to persons with signature authority over a foreign financial account, but no financial interest in the account.
IRS Eliminates Form 5472 Duplicate Filing Requirement
The IRS issued temporary and proposed regulations to remove the duplicate filing requirement for Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.
Foreign Disregarded Entities May Face U.S. FICA Tax Issue
This item shows how restructuring international businesses to operate through entities disregarded for U.S. federal income tax purposes may also affect the employment tax treatment of the organization’s individual employees.
Emerging Issues for Non-U.S. Shareholders in Corporate Inversions
This item discusses significant potential tax issues for foreign investors that invest in a foreign IPO that is related to the inversion of a U.S. company.
IRS Issues Foreign Financial Account Reporting Guidance
The IRS issued a second notice giving guidance on various reporting requirements under the Foreign Account Tax Compliance Act.
Offshore Voluntary Disclosure Initiative
The IRS announced another special voluntary disclosure initiative designed to bring U.S. persons hiding assets offshore back into the U.S. tax system. This item discusses some of the issues related to the IRS effort to bring U.S. persons into compliance.
The Education, Jobs, and Medicaid Assistance Act of 2010
This item explains significant changes to foreign tax credits made by the Education, Jobs, and Medicaid Assistance Act of 2010.
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.
