International Tax
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.
This discussion explores certain issues that multinationals should consider when deciding whether to use Malta as part of their worldwide operations.
The difference in valuation standards between financial reporting and transfer pricing leads to the use of different valuation methods for each. This may significantly affect the valuation of the asset for transfer-pricing purposes.
This discussion explores key considerations to keep in mind for claiming customs duty refunds on transfer-pricing adjustments.
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.
New procedures will facilitate residency certification where the Internal Revenue Service has not yet processed the applicant’s tax return.
The tax advantages available in Puerto Rico have recently captured the interest of both taxpayers and the IRS.
What partnerships, S corporations, and others with foreign partnership interests need to know for tax year 2021 and beyond.
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.
Final and proposed regulations cover PFIC and CFC stock held through domestic partnerships and S corporations.
The IRS announced that it will amend the regulations under Secs. 1446(a) and 1446(f) to defer the applicability date of certain provisions by one year to Jan. 1, 2023.
The IRS permitted a taxpayer effectively to undo planning undertaken during the so-called gap period (described later).
The Senate Finance Committee’s text includes changes from the House’s version of the bill, including a removal of the House’s increase in the SALT deduction cap.
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.
A U.S. taxpayer living abroad was not entitled to take a foreign tax credit against her net investment income tax based on provisions in the United States–France and United States–Italy tax treaties.
For a limited time, the IRS is allowing automatic change procedures for CFCs changing to the ADS method and has clarified the process and certain aspects of audit protection.
The IRS issued Rev. Proc. 2021-26, which contains procedures for certain foreign corporations to obtain automatic consent to change their methods of accounting for depreciation to the alternative depreciation system.
This item focuses on the potential increase in the Sec. 904(a) foreign tax credit limitation when PTEP
is distributed by a CFC to its corporate “U.S. shareholder.”
The penalty for failure to report a distribution from a foreign trust is not reduced when the trust beneficiary is also the trust owner.
