International Tax

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.

Virtual currency not FBAR reportable (at least for now)

The AICPA Virtual Currency Task Force reached out to Treasury’s Financial Crimes Enforcement Network (FinCEN) to help practitioners answer the question of whether virtual currency (or cryptocurrency) must be reported on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

Newsletter Articles

TAX REFORM

Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.

DEDUCTIONS

Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.