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.
Sec. 267A: Certain related-party amounts paid or accrued in hybrid transactions or with hybrid entities
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.
This article alerts the practitioner to when an information return may be necessary.
Although a company might in the future receive a refund of foreign taxes paid, it was entitled to claim foreign tax credits.
The IRS published a FATCA FAQ to establish a temporary standard of independence until it can provide comprehensive guidance.
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.