International Tax
The IRS issued proposed regulations implementing Sec. 951A’s global intangible low-taxed income provision, which requires a US shareholder of a controlled foreign corporation to include this income in the shareholder’s gross income.
Three recent cases provide tips to decide if it’s worth the time and effort to appeal to the Tax Court.
The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings.
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.
This item discusses provisions of the TCJA that seek to curb the erosion of the U.S. tax base.
A change to the Code limits the ability of shareholders of certain foreign insurance companies to avoid being subject to antideferral rules that apply to passive foreign investment companies.
This item discusses uncertainties regarding the
consequences of a midyear distribution
of PTI by a CFC.
Determining how to “properly attribute” a foreign
income tax to an income inclusion is unclear, particularly with respect to Sec. 956 inclusions.
Appropriately capitalizable costs under Sec. 263A generally are not considered base-erosion payments
for purposes of the BEAT.
This item explores whether the toll charge might
be treated as a recognized built-in gain under Sec. 382(h).
A German citizen’s failure to establish that he was a resident of Germany meant he was a “covered expatriate” liable for tax on stock sale gains.
The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings.
In many instances, the new repatriation tax will produce harsh results for flowthrough taxpayers.
Imposition of a base-erosion and anti-avoidance tax adds fresh complexity to the calculation of transfer-pricing tax and accounting results.
It appears that Sec. 267A allows a taxpayer to deduct a disqualified related-party amount if the amount is not paid pursuant to a hybrid transaction or paid by or to a hybrid entity.
The IRS is ending the Offshore Voluntary Disclosure Program just as its enforcement of cryptocurrency compliance increases.
FinCEN issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts.
The IRS announced that it is closing the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.
Under Sec. 911, a U.S. citizen whose tax home is in one or more foreign countries, who spends enough there, can exclude a certain amount of foreign earned income.
