Non-Resident Withholding

No employer refund for tax payments made on employee’s behalf

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.

IRS extends withholding date for certain PTP transfers, distributions

The IRS announced that it will amend the regulations under Secs. 1446(a) and 1446(f) to defer the applicability date of certain provisions by one year to Jan. 1, 2023.

Failure-to-deposit penalty when tax is not withheld on payments of US-source income

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.

Sec. 1446(f) regulations: The rules and unanswered questions

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.

Buyer’s withholding obligation under FIRPTA

This article discusses some details of the Foreign Investment in Real Property Tax Act of 1980.

Tax Insider Articles

Tax Clinic

Inflation Reduction Act includes 15% corporate minimum tax on book income

Private foundations’ distributions to and from nonpublic charities

Supporting organization loses tax-exempt status

Sec. 987 foreign currency regulations applicability date extended again

The Inflation Reduction Act’s energy- and climate-related tax provisions

DEDUCTIONS

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.

TAX RELIEF

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.

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