This item discusses punitive tarriffs.
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.
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.
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.
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.
The IRS proposed regulations to clarify how to classify transactions involving digital content and cloud computing.
The IRS released guidance to further recap and clarify the rules for transfer and consent agreements.
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, or CFC.
Individuals, who are not afforded the benefit of using indirect foreign tax credits, are unable to reduce their Sec. 965 liability with foreign taxes generated at the foreign company level.
This discussion provides a summary of some of the basic previously taxed earnings and profits ordering rules likely to apply to distributions made by controlled foreign corporations .
This item summarizes the complexities of a digitalized economy for MNCs and considers the multifaceted implications to U.S. MNCs with respect to financial statements and tax reporting.
The IRS announced procedures to allow certain individuals who have renounced their US citizenship to get into compliance with their U.S. tax obligations and obtain relief for back taxes.
Partnerships will need to establish procedures to deal with secondary withholding in the event that transferees do not withhold or collect the appropriate documentation.
This discussion focuses on how state worldwide reporting works and what taxpayers should consider in determining whether to elect it or avoid it.
The Internal Revenue Service proposed regulations to clarify how to classify transactions involving digital content and cloud computing.
Sec. 250 allows domestic corporations a deduction for their “foreign-derived intangible income.” Proposed regulations that were issued earlier this year answer many outstanding questions regarding the calculation of this new deduction but also include documentation requirements that may prove onerous for some taxpayers.
The final rule allows a RIC invested in CFCs and PFICs to treat the required CFC inclusion or PFIC inclusion respectively, as qualifying income for purposes of a RIC’s qualifying income test.
This discussion focuses on the GILTI and BEAT implications for the benefit received by a U.S. corporation reporting a worthless stock deduction under Sec. 165(g) for a CFC’s stock.
The IRS issued proposed regulations on the operation of new Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from the sale or exchange of certain partnership interests).
Before transferring Sec. 987 QBUs to related domestic or foreign parties, practitioners should consider the tax implications of the May final regulations.