This article discusses issues that have evolved around FDII where there has been little guidance and outlines ways to better take advantage of the FDII regime.
The plain language of the statute allowed taxpayers to shelter income from all tax using a foreign sales corporation and Roth IRAs.
As SPAC activity has increased, non-U.S.-domiciled SPACs have become more prevalent and carry major U.S. tax-compliance ramifications due to their potential treatment as a PFIC for U.S. investors.
This item provides an overview of potential penalties and presents an argument as to why the Sec. 6656 failure-to-deposit penalty may not apply in some instances.
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.
Importers should consider transfer-pricing arrangements in advance, based on the totality of the circumstances, to assess any potential refund of duties on adjusted prices to imported goods.
Certain U.S. citizens and U.S. residents doing business abroad can have surprising tax reporting obligations as a consequence of the IRS's revised instructions to Form 8858.
This article summarizes the options available to taxpayers to come into compliance with FBAR and information reporting obligations.
This article addresses certain aspects of the withholding rules of the final Sec. 1446(f) regulations, options to eliminate or reduce Sec. 1446(f) withholding, and some outstanding issues.
This item provides an overview of the federal tax rules that apply to debt modifications and restructurings, with a primary focus on how U.S. corporate shareholders of CFCs are affected.
As the IRS focuses more attention on Sec. 965, it is vital that taxpayers with Sec. 965 tax liabilities and their advisers understand the potentially applicable periods of limitation on assessment.
This discussion outlines the basics of sales and use tax and transfer pricing, considers how intercompany transfer pricing may unintentionally lead to sales tax exposure, and offers steps to avoid audit assessments and penalties.
The IRS issued final rules on the Sec. 245A extraordinary disposition rule and the Sec. 951A disqualified basis and disqualified payment rules, as well as reporting requirements to facilitate the rules.
Under the Subpart F regime, income subject to the regime is initially defined by what it includes, while under the GILTI regime, income subject to the regime is initially defined by what it excludes. This article discusses the application of these different approaches in the context of nonliquidating distributions from a controlled foreign corporation to a U.S. shareholder.
This item discusses how new rules would affect taxpayers’ ability to claim FTCs for foreign income taxes that are offset with refundable tax credits in a foreign jurisdiction.
MNEs will need to reevaluate their pre-pandemic transfer-pricing approach based on an updated application of the arm’s-length principle and be prepared to defend changes in the approach and results.
IRS Notice 2020-69 provided a new entity election that allows an S corporation to compute the deemed inclusions at the entity level, as opposed to at the shareholder level. This item provides background on the new election, illustrates its effects, and highlights opportunities and traps to consider when contemplating the election.
In FAA 20204201F, the IRS concluded that the Sec. 704(c) allocation method adopted by a partnership between a U.S. corporation and its domestic and foreign affiliates was unreasonable under the Sec. 704(c) anti-abuse rule.
This discussion summarizes proposed regulations that would coordinate two sets of rules that apply to extraordinary dispositions and disqualified transfers of property.