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.
This item discusses three options to achieve rollover equity when purchasing a Canadian company.
This article discusses some requirements of Form 1116 and the adjustments’ directions as laid out in Publication 514.
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
To qualify for a certain automatic extension, the taxpayer can attach a statement to a return showing that it is a foreign corporation that maintains an office or place of business in the United States.
The 2016 regulations put partners on notice that Sec. 987 principles generally apply to partnership assets and liabilities.
The gain on a sale could be subject to U.S. federal income tax.
It is important to understand compliance requirements should the IRS begin using the sailing permit to aid its collection efforts.
The Tax Court held that the IRS’s determination, using a discounted-cashflow method, of the value of a CSA buy-in payment for Amazon.com’s transfer to a subsidiary of the right to use certain preexisting intangible assets in Europe was arbitrary, capricious, and unreasonable.
This article focuses on the mechanics of the “cleansing” process and the associated advantages and potential pitfalls.
This item covers how MOSS operates and explains why certain provisions need to be amended.
The consideration of a border tax adjustment on goods imported may persuade multinational businesses to reevaluate their intercompany supply chain, having transfer-pricing implications.