International Tax

Topics

July 21, 2020

GILTI rules address income subject to high foreign tax rate

The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.

July 9, 2020

FDII and GILTI regulations finalized

The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.

July 1, 2020

Taxpayer avoids Sec. 954(d)(1) Scylla but not Sec. 954(d)(2) Charybdis

A US company’s income earned by a Luxembourg
subsidiary from sales of products made by a Mexican branch of the subsidiary is taxable as foreign base company sales income under Subpart F.

July 1, 2020

Reducing GILTI liability using CFC accounting method change procedures

Methods of accounting may be an effective tool in tax planning for GILTI; however, method change procedures for CFCs differ from procedures for domestic taxpayers.

June 1, 2020

Taxpayer’s failure to report foreign accounts was willful

Willful FBAR penalties upheld because taxpayer exhibited willful blindness of or recklessly violated
the FBAR reporting requirements.

June 1, 2020

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.

May 14, 2020

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.

May 1, 2020

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.

May 1, 2020

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.

May 1, 2020

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.

April 22, 2020

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.

April 1, 2020

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.

March 20, 2020

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.

March 12, 2020

Foreign gifts: A common example of undisclosed foreign transactions

Here’s what may happen when a foreign gift has not been disclosed.

March 1, 2020

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.

March 1, 2020

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.

March 1, 2020

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.

February 1, 2020

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.

February 1, 2020