The use of information reporting to prevent tax avoidance has been a major focus of the current administration and the IRS.
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International Tax
Congress Votes to Limit Use of Foreign Tax Credits – H.R. 1586
Congress enacted legislation that makes changes to the how corporations can use the foreign tax credit.
Investing in Canada Through an LLC
This item examines the Canadian Tax Court’s opinion in TD Securities (USA) LLC as well as how it will affect the amendments under the Fifth Protocol to the Canada-U.S. treaty.
New VAT Rules Regarding International Services
This item focuses on recent European Union (EU) VAT legislative changes and how they will affect the provision of international services.
Application of Sec. 1297(d) Overlap Rule to PFIC Shares Held by a U.S. Partnership
Letter Ruling 200943004 provides helpful insight into IRS thinking with respect to the application of the PFIC/CFC overlap rule in the partnership context.
Application of Entity Classification Elections to Shelf Company Acquisitions
When electing the entity classification of a newly acquired foreign shelf company, the taxpayer must consider several procedural issues.
Special Reporting Requirements for U.S. Domestic Use of U.K. Dual Consolidated Loss
A U.S. corporation that incurs a dual consolidated loss (DCL) generally is prohibited from using the loss to reduce U.S. taxable income. If the DCL is from a loss incurred by a company organized under the laws of the United Kingdom, the U.S. company must comply with additional reporting requirements because of the U.K. mirror legislation.
The HIRE Act and the IRS Address Dividend Equivalent Payments on Equity Swaps
The taxation of equity total return swaps (TRSs) held by a foreign investor not subject to U.S. federal net income tax has been the subject of many wide-ranging audits in recent years. The issue is whether any dividend-equivalent payments made under the terms of a TRS are subject to the 30% gross withholding tax or to a reduced amount under an applicable tax treaty.
Extraterritorial Income Benefits May Still Be Alive
Recent IRS guidance confirms that the ETI benefit may still be available for income that taxpayers recognized in post-2006 years from certain transactions occurring before the ETI regime was repealed.
U.S.-Switzerland Protocol Will Allow Handover of UBS Account Holder Information
The United States and Switzerland announced a new protocol to allow the Swiss government to provide information to the IRS on U.S. account holders of Swiss bank UBS.
Global Tax Treatment of Equity Awards
Careful consideration is needed before a company begins to issue long-term incentives in foreign tax jurisdictions.
Congress Enacts Hiring Incentives Act with Tax Provisions
The Hiring Incentives to Restore Employment Act contains several tax items, the biggest of which is a payroll tax credit for employers who hire workers who have been unemployed for at least 60 days and who are not replacement hires.
IRS Provides Guidance on Deemed Dispositions by Canadian Emigrants
The IRS has issued guidance for individuals who emigrate from Canada and wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Rev. Proc. 2010-19).
The Software Regulations and Subpart F
The proper U.S. tax treatment of a sale or license of computer programs through a foreign subsidiary is challenging and potentially expensive in cash taxes. A practitioner must consider a variety of aspects and value exchanged in transactions and transfers when assessing transactions in software.
Profile of Multinational Businesses with Inbound Investments
Growth in international business brings increased opportunities for CPA firms to provide accounting and tax services. This article focuses on multinational businesses with inbound investments—i.e., foreign investors with business operations in the United States.
New Rules on Treatment of Certain Stock of a Foreign Corporation Under Sec. 7874
The IRS announced its intention to issue regulations that will identify certain stock of a foreign corporation that is to be disregarded for determining foreign corporation ownership under the requirements of Sec. 7874
Significant Recent Corporate Developments
This article discusses selected developments in U.S. federal income taxation of corporations and consolidated groups during 2009.
International Tax Compliance for Auditors and CFOs
In an environment where international tax examinations will play a larger role in tax audits, prudent financial executives and auditors will take the time to evaluate their current international tax compliance, assess any shortcomings, and correct them.
FBARs and Not-Yet-Reported Offshore Income: Penalties and Practitioners’ Issues
This item considers (1) options available for the client that did not disclose under the IRS’s voluntary disclosure program, which ended October 15, 2009; (2) practitioners’ responsibilities, including tax organizers and engagement letters; and (3) items suspended and/or extended to the June 2010 due date.
IRS Focuses on the FBAR
FBAR has graduated from a little-known filing requirement to a priority issue that should be at the top of every tax return preparer’s checklist.
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.
