Corporate AMT: Unanswered questions about its foreign tax credit
Key issues related to the corporate AMT FTC are unsettled and could have a significant effect on a taxpayer’s corporate AMT liability.
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Key issues related to the corporate AMT FTC are unsettled and could have a significant effect on a taxpayer’s corporate AMT liability.
The Supreme Court held that the $10,000 maximum penalty for the nonwillful failure to file a compliant report applies on a per-report, not a per-account, basis.
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
On Aug. 15, 2022, the IRS announced that it intends to defer by one more year the applicability date of certain foreign currency regulations under Sec. 987.
The IRS announced that it will issue proposed regulations providing some relief to brokers that are required to withhold on the transfer of an interest in a publicly traded partnership (PTP) if the PTP is a foreign-traded entity.
Proposed foreign tax credit regulations provide guidance on the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery requirement, and the application of the source-based attribution requirement to withholding tax on royalty payments.
A taxpayer cannot the avoid consequences of a closing agreement.
This item clarifies the various categories of income inclusions a U.S. shareholder of a CFC may need to consider to the extent of its current-year earnings and profits or deficits and how to properly report and track any foreign inclusions related to E&P.
U.S. persons (citizens and permanent residents) whose financial matters extend overseas may face a tax situation that virtually no other country’s nationals do.
The Third Circuit affirmed a district court’s holding that a taxpayer’s failure to report his foreign accounts on FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (FBAR), was willful.
The IRS provides relief for taxpayers who would have qualified for the foreign earned income exclusion in 2019 and 2020 but for COVID-19.
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
By agreeing to hear a Romanian-born businessperson’s appeal, the Supreme Court will address a circuit split over how to stack maximum penalties for multiple nonwillful civil violations for failure to file the FBAR.
A document issued Thursday by Treasury offers clarity related to, for example, tax and management consulting services that would not be prohibited by the U.S. sanctions announced last month.
The IRS determined that an employer funding an international assignee’s federal income tax obligations under a tax equalization policy may not seek a refund of excess withholding on that employee’s compensation.
There are a number of pitfalls that beset taxpayers seeking to access MAP and to implement MAP resolutions.
Regulations provide regulatory authority for Treasury’s long-held position that an individual taxpayer who elects on a timely filed return to claim the foreign tax credit on the cash basis may not change to the accrual basis on an amended return.
For foreign tax credit purposes, a corporation must use the same method to characterize shares in a CFC that the CFC used to apportion its interest expense.
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
This item explores DEMPE and points out significant differences between the OECD Guidelines and the Treasury regulations under Sec. 482, concerning DEMPE and risk.
DEDUCTIONS
Business meal deductions after the TCJA
This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.
TAX RELIEF
Quirks spurred by COVID-19 tax relief
This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.