Treaties may have exceptions to saving clauses that benefit U.S. persons in terms of their U.S. income taxes.
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
This column discusses the portions of the act likely to affect the typical inbound real estate investment structure.
This column summarizes the federal tax law changes under reform enacted in December.
Tax Court granted the government’s motion for summary judgment that intercompany transactions between a U.S. parent's CFCs and its domestic subsidiaries resulted in the CFCs holding U.S. property.
This extension continues the status quo for a number of provisions through 2018 and provides a one-year extension on many transition aspects.
A pilot who lived at a hotel in South Korea while there for his job was not entitled to the foreign earned income exclusion because he had not proved that he was a bona fide resident.
This last article in a three-part series contains an analysis of the tax reporting of the net income distribution to a U.S. beneficiary of a foreign nongrantor trust.
The House’s tax reform bill would make many changes to the taxation of US companies’ foreign subsidiaries.
This article provides an introduction to Sec. 956 inclusions.
Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.
Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.
This item explains how the statute of limitations may affect a taxpayer when claiming a refund or credit on an overpayment through amended tax returns while under the OVDP.
Employees should have overarching guidance for their global assignment that includes international assignment agreements.
For reasons other than U.S. income tax, these transactions could be structured as sales of U.S. stock among foreign affiliates.
This item discusses treaty benefit limitations on U.S.-source FDAP income with respect to hybrid entities and procedural requirements of obtaining treaty benefits.
This item looks at ongoing IRS guidance.
Non-U.S. taxpayers generally are surprised by the degree of complexity involved in complying with U.S. state and local taxes.
This item illustrates how challenging it can be to use foreign tax credits on qualified dividends.
The Tax Court held that the loan portion of a STARS transaction was not a sham but that the company was subject to tax penalties.