Willful FBAR penalties upheld because taxpayer exhibited willful blindness of or recklessly violated
the FBAR reporting requirements.
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Topics
International Tax
Withholding and reporting of partnership distributions to non-US partners
The mechanics of the withholding regime seem straightforward, but they can be difficult for certain
tiered partnership structures.
Foreign trust reporting: Beware of late-filing penalties
Late-filing penalties for foreign trust filings can be devastating to clients and a significant challenge to CPAs trying to explain or eliminate them.
Section 301 China tariffs: Where things stand
This item discusses the back-and-forth negotiations and tit-for-tat tariff increases leading to significant
economic tensions between the U.S. and China.
Puerto Rico: A permanent tax deferral in a GILTI world?
Under the right set of circumstances, there may be a significant opportunity for tax savings in Puerto Rico.
Foreign pension plans and the US-UK tax treaty
Whether contributions, earnings, and distributions are includible in the taxpayer’s income depends on the type of foreign pension plan and whether a tax treaty exempts an event that is otherwise taxable.
Relief for tax residency impacts of COVID-19 travel disruptions
Individuals and businesses can avoid having their prolonged stay in a country affect their tax residence if their cross-border travel was disrupted by the COVID-19 pandemic, under limited relief the IRS announced in two revenue procedures and FAQs.
Individual election to be taxed at corporate rates
Until now, shareholders had rarely invoked the Sec. 962 election to be taxed at corporate rates, and, as a result, most states have provided no specific guidance on how to treat a Sec. 962 election for state income tax purposes.
Final regulations address covered assets acquisition rules
The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.
Foreign gifts: A common example of undisclosed foreign transactions
Here’s what may happen when a foreign gift has not been disclosed.
Crime doesn’t pay — and may be taxable under Subpart F
One potentially important component of Subpart F
income under Sec. 952(a)(4) is illegal bribes, kickbacks, or other payments made by or on behalf of a CFC to a foreign government official, employee, or agent.
Country-by-country reporting: Considerations facing US multinationals
As the OECD member states plan to review the
CbC framework in 2020, this discussion highlights several common issues large U.S. MNEs may face.
IRS issues guidance on BEAT
The IRS issued detailed guidance on the Sec. 59A base-erosion and anti-abuse tax (BEAT), which was added to the Code by the law known as the Tax Cuts and Jobs Act.
Update on OECD’s proposals: Pillars 1 and 2
Issues raised in pillars 1 and 2 of the OECD consultation documents resemble issues being addressed at the state and local tax level in the United States.
Cross-border M&As post-TCJA: Three things advisers should know
This item highlights three often overlooked or misunderstood factors potentially disrupting international transactions.
New US duties on certain EU and Chinese goods
This item discusses punitive tarriffs.
Relief procedures for certain people planning to renounce US citizenship
The procedures allow qualifying former U.S. citizens who have relinquished U.S. citizenship to comply with their U.S. income tax and reporting obligations without paying any unpaid taxes and penalties.
Unintended CFC downward attributions get safe harbor
U.S. shareholders who own stock in foreign corporations were given a safe harbor by the IRS, making it easier for them to establish that they are not shareholders in a controlled foreign corporation.
Final regs. issued on foreign tax credits
The IRS officially released final regulations providing guidance on determining foreign tax credits. The regulations include changes necessitated by the law known as the Tax Cuts and Jobs Act.
BEAT regs. are finalized, new regs. are proposed
The IRS issued detailed guidance on the Sec. 59A base-erosion and anti-abuse tax (BEAT), which was added to the Code by the law known as the Tax Cuts and Jobs Act.
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.
