This item explains significant changes to foreign tax credits made by the Education, Jobs, and Medicaid Assistance Act of 2010.
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International Tax
Form 5471 Penalties
This item discusses the importance of timely filing federal income tax returns that include Form 5471, regardless of whether the return shows a balance due, because of the extensive penalties for failure to comply with the reporting requirements.
Second Offshore Voluntary Disclosure Program Started
The IRS has announced that it is starting a new program designed to bring money held in foreign accounts back into the U.S. tax system and to help taxpayers with income from offshore accounts comply with federal tax law.
FinCEN Amends BSA Regs on FBAR Filings
FinCEN amended the FBAR regulations to clarify when an account is foreign and therefore reportable as a foreign financial account and the definition of key terms like “signature or other authority.”
IRS Announces Second Offshore Voluntary Disclosure Program
The IRS announced that it is starting a new program designed to bring money held in foreign accounts back into the U.S. tax system and to help taxpayers with income from offshore accounts to comply with federal tax law.
New Procedures Permitting Prepayment Review of International Information Reporting Penalties
The authors review the recently published new Internal Revenue Manual (IRM) Section 8.11.5, which permits taxpayers that have been assessed certain international information reporting penalties to elect prepayment review of those penalties by IRS Appeals.
Cost-Sharing Agreements and the Arm’s-Length Standard
The Xilinx case has created turmoil in the international tax community for quite some time, and there is no clear end in sight. Although the Ninth Circuit reversed its controversial decision, uncertainty surrounds the validity of Treasury’s new regulations explicitly requiring that cost sharing include stock options.
The HIRE Act of 2010
In March 2010, Congress enacted the Hiring Incentives to Restore Employment Act, which includes provisions to encourage employers to hire new employees and to make new capital investments. This article discusses these new incentives, as well as the revenue-raising provisions included in the act to offset their cost.
Scope of Foreign Trust Provisions in the HIRE Act
This article analyzes the foreign trust provisions of the HIRE Act and offers some practical guidance for practitioners to consider in their development of best practice procedures.
FATCA: Should U.S. Financial Institutions Be Concerned?
The Foreign Account Tax Compliance Act requires foreign financial institutions to identify U.S. account holders and reveal details about their accounts to the IRS.
Congress Votes to Limit Use of Foreign Tax Credits
P.L. 111-226 makes changes to how corporations can use the foreign tax credit and also terminates the advance refundability of the earned income credit (under Sec. 3507), effective for tax years beginning after December 31, 2010.
Focus on Tax Avoidance Leads to Changes in Foreign Reporting Requirements
The use of information reporting to prevent tax avoidance has been a major focus of the current administration and the IRS.
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.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
