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.
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International Tax
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.
IRS eases application process for US residency certification
New procedures will facilitate residency certification where the Internal Revenue Service has not yet processed the applicant’s tax return.
Puerto Rico residents: Scope of income tax exemption for capital gains
The tax advantages available in Puerto Rico have recently captured the interest of both taxpayers and the IRS.
Complying with new schedules K-2 and K-3
What partnerships, S corporations, and others with foreign partnership interests need to know for tax year 2021 and beyond.
Tax credit did not independently arise under treaties
Given the proliferation of use of the model treaty language, most U.S. citizens living abroad will continue to find a foreign tax credit unavailable against their net investment income, even when that income is taxed by other countries.
Final regulations affect owners of foreign stock
Final and proposed regulations cover PFIC and CFC stock held through domestic partnerships and S corporations.
IRS extends withholding date for certain PTP transfers, distributions
The IRS announced that it will amend the regulations under Secs. 1446(a) and 1446(f) to defer the applicability date of certain provisions by one year to Jan. 1, 2023.
Reversing a gap period transaction through late check-the-box election
The IRS permitted a taxpayer effectively to undo planning undertaken during the so-called gap period (described later).
Senate Finance Committee releases tax provisions of Build Back Better Act
The Senate Finance Committee’s text includes changes from the House’s version of the bill, including a removal of the House’s increase in the SALT deduction cap.
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.
