International Tax

Supreme Court to resolve FBAR penalty dispute

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.

IRS’s FATCA enforcement fell short, TIGTA says

Initial plans for the Foreign Account Tax Compliance Act’s regime of reporting US taxpayers’ foreign bank accounts and other financial assets largely have stalled, the Treasury Inspector General for Tax Administration reports.

Tax credit did not independently arise under treaties

Given the proliferation of use of the model treaty language, most U.S. citizens living abroad will continue to find a foreign tax credit unavailable against their net investment income, even when that income is taxed by other countries.

Tax provisions in the Build Back Better Act

The Build Back Better Act contains a large number of tax provisions, ranging from an extension of the advance child tax credit, to a wide variety of green energy tax incentives, and a minimum tax on corporations.

Tax Insider Articles

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.