International Tax
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.
U.S. persons (citizens and permanent residents) whose financial matters extend overseas may face a tax situation that virtually no other country’s nationals do.
The Third Circuit affirmed a district court’s holding that a taxpayer’s failure to report his foreign accounts on FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (FBAR), was willful.
The IRS provides relief for taxpayers who would have qualified for the foreign earned income exclusion in 2019 and 2020 but for COVID-19.
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
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.
The IRS determined that an employer funding an international assignee’s federal income tax obligations under a tax equalization policy may not seek a refund of excess withholding on that employee’s compensation.
There are a number of pitfalls that beset taxpayers seeking to access MAP and to implement MAP resolutions.
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.
For foreign tax credit purposes, a corporation must use the same method to characterize shares in a CFC that the CFC used to apportion its interest expense.
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
This item explores DEMPE and points out significant differences between the OECD Guidelines and the Treasury regulations under Sec. 482, concerning DEMPE and risk.
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.
