International Tax

Final regs. issued on foreign tax credits

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.

CFC downward attributions get safe harbors

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.

Demystifying the new international E&P rules

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 .

IRS offers expatriate tax relief

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.

Foreign-derived intangible income guidance addresses many open questions

Sec. 250 allows domestic corporations a deduction for their “foreign-derived intangible income.” Proposed regulations that were issued earlier this year answer many outstanding questions regarding the calculation of this new deduction but also include documentation requirements that may prove onerous for some taxpayers.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

PRACTICE MANAGEMENT

2019 tax software survey

This annual survey shows how CPAs rate the tax preparation software they used during last tax season and how it handled the recent tax law changes.