International Tax

Proposed regulations provide guidance on foreign tax credit rules

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.

CFCs: US shareholders’ income inclusions

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.

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.

Foreign tax credit: Changing from cash to accrual basis

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.

OECD DEMPE and risk guidance in the US

This item explores DEMPE and points out significant differences between the OECD Guidelines and the Treasury regulations under Sec. 482, concerning DEMPE and risk.

Tax Insider Articles


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.


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.