The IRS announced that it will issue proposed regulations providing some relief to brokers that are required to withhold on the transfer of an interest in a publicly traded partnership (PTP) if the PTP is a foreign-traded entity.
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International Tax
Proposed regulations provide guidance on foreign tax credit rules
Proposed foreign tax credit regulations provide guidance on the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery requirement, and the application of the source-based attribution requirement to withholding tax on royalty payments.
Engineer cannot escape closing agreement
A taxpayer cannot the avoid consequences of a closing agreement.
CFCs: US shareholders’ income inclusions
This item clarifies the various categories of income inclusions a U.S. shareholder of a CFC may need to consider to the extent of its current-year earnings and profits or deficits and how to properly report and track any foreign inclusions related to E&P.
US clients with international tax issues: Five helpful tips
U.S. persons (citizens and permanent residents) whose financial matters extend overseas may face a tax situation that virtually no other country’s nationals do.
Counsel’s admission costly to taxpayer in FBAR case
The Third Circuit affirmed a district court’s holding that a taxpayer’s failure to report his foreign accounts on FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (FBAR), was willful.
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
Foreign earned income exclusion: Pandemic-related relief
The IRS provides relief for taxpayers who would have qualified for the foreign earned income exclusion in 2019 and 2020 but for COVID-19.
Supreme Court to resolve FBAR penalty dispute
By agreeing to hear a Romanian-born businessperson’s appeal, the Supreme Court will address a circuit split over how to stack maximum penalties for multiple nonwillful civil violations for failure to file the FBAR.
Certain tax services do not violate US ban on provision of accounting services in relation to Russia sanctions
A document issued Thursday by Treasury offers clarity related to, for example, tax and management consulting services that would not be prohibited by the U.S. sanctions announced last month.
OECD DEMPE and risk guidance in the US
This item explores DEMPE and points out significant differences between the OECD Guidelines and the Treasury regulations under Sec. 482, concerning DEMPE and risk.
Secondary transfer-pricing adjustments
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
Transfer pricing and MAP: Common traps for the unwary
There are a number of pitfalls that beset taxpayers seeking to access MAP and to implement MAP resolutions.
Foreign tax credit: Changing from cash to accrual basis
Regulations provide regulatory authority for Treasury’s long-held position that an individual taxpayer who elects on a timely filed return to claim the foreign tax credit on the cash basis may not change to the accrual basis on an amended return.
No employer refund for tax payments made on employee’s behalf
The IRS determined that an employer funding an international assignee’s federal income tax obligations under a tax equalization policy may not seek a refund of excess withholding on that employee’s compensation.
Foreign tax credit requires consistency
For foreign tax credit purposes, a corporation must use the same method to characterize shares in a CFC that the CFC used to apportion its interest expense.
Customs duty refunds on transfer-pricing adjustments
This discussion explores key considerations to keep in mind for claiming customs duty refunds on transfer-pricing adjustments.
Considerations for multinationals with US and Maltese operations
This discussion explores certain issues that multinationals should consider when deciding whether to use Malta as part of their worldwide operations.
Differences between transfer pricing and financial reporting valuations
The difference in valuation standards between financial reporting and transfer pricing leads to the use of different valuation methods for each. This may significantly affect the valuation of the asset for transfer-pricing purposes.
IRS’s FATCA enforcement fell short, TIGTA says
Initial plans for the Foreign Account Tax Compliance Act’s regime of reporting US taxpayers’ foreign bank accounts and other financial assets largely have stalled, the Treasury Inspector General for Tax Administration reports.
TAX PRACTICE MANAGEMENT
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