International Tax
Until now, shareholders had rarely invoked the Sec. 962 election to be taxed at corporate rates, and, as a result, most states have provided no specific guidance on how to treat a Sec. 962 election for state income tax purposes.
The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.
Here’s what may happen when a foreign gift has not been disclosed.
As the OECD member states plan to review the
CbC framework in 2020, this discussion highlights several common issues large U.S. MNEs may face.
One potentially important component of Subpart F
income under Sec. 952(a)(4) is illegal bribes, kickbacks, or other payments made by or on behalf of a CFC to a foreign government official, employee, or agent.
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.
This item highlights three often overlooked or misunderstood factors potentially disrupting international transactions.
Issues raised in pillars 1 and 2 of the OECD consultation documents resemble issues being addressed at the state and local tax level in the United States.
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.
