Which taxpayers are potentially subject to the new ‘BEAT’?
Imposition of a base-erosion and anti-avoidance tax adds fresh complexity to the calculation of transfer-pricing tax and accounting results.
International Tax
Sec. 267A: Certain related-party amounts paid or accrued in hybrid transactions or with hybrid entities
It appears that Sec. 267A allows a taxpayer to deduct a disqualified related-party amount if the amount is not paid pursuant to a hybrid transaction or paid by or to a hybrid entity.
The Offshore Voluntary Disclosure Program and cryptocurrency
The IRS is ending the Offshore Voluntary Disclosure Program just as its enforcement of cryptocurrency compliance increases.
Filing deadline for 2017 FBARs same as for individual tax returns
FinCEN issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts.
Offshore Voluntary Disclosure Program to end in September
The IRS announced that it is closing the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.
The physical presence test for excluding foreign earned income
Under Sec. 911, a U.S. citizen whose tax home is in one or more foreign countries, who spends enough there, can exclude a certain amount of foreign earned income.
Transnational tax information reporting: A guide for the perplexed
This article alerts the practitioner to when an information return may be necessary.
Coca-Cola entitled to credits for overpaid Mexican taxes
Although a company might in the future receive a refund of foreign taxes paid, it was entitled to claim foreign tax credits.
External reviewer independence requirements and the 2017 QI Agreement
The IRS published a FATCA FAQ to establish a temporary standard of independence until it can provide comprehensive guidance.
Tax treaty benefits for U.S. citizens and residents
Treaties may have exceptions to saving clauses that benefit U.S. persons in terms of their U.S. income taxes.
FinCEN announces filing deadline for 2017 FBARs
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
How inbound real estate investors are treated under the Tax Cuts and Jobs Act
This column discusses the portions of the act likely to affect the typical inbound real estate investment structure.
Congress enacts tax reform
This column summarizes the federal tax law changes under reform enacted in December.
U.S. parent’s CFCs held U.S. property under Sec. 956 as result of intercompany transactions
Tax Court granted the government’s motion for summary judgment that intercompany transactions between a U.S. parent's CFCs and its domestic subsidiaries resulted in the CFCs holding U.S. property.
Implementation of certain parts of Sec. 871(m) regs. delayed a year
This extension continues the status quo for a number of provisions through 2018 and provides a one-year extension on many transition aspects.
Pilot grounded on foreign income exclusion
A pilot who lived at a hotel in South Korea while there for his job was not entitled to the foreign earned income exclusion because he had not proved that he was a bona fide resident.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 3
This last article in a three-part series contains an analysis of the tax reporting of the net income distribution to a U.S. beneficiary of a foreign nongrantor trust.
Foreign income provisions in the Tax Cuts and Jobs Act
The House’s tax reform bill would make many changes to the taxation of US companies’ foreign subsidiaries.
Look out for Sec. 956 inclusions
This article provides an introduction to Sec. 956 inclusions.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 2
Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.
