Given the proliferation of use of the model treaty language, most U.S. citizens living abroad will continue to find a foreign tax credit unavailable against their net investment income, even when that income is taxed by other countries.
A U.S. taxpayer living abroad was not entitled to take a foreign tax credit against her net investment income tax based on provisions in the United States–France and United States–Italy tax treaties.
Whether contributions, earnings, and distributions are includible in the taxpayer’s income depends on the type of foreign pension plan and whether a tax treaty exempts an event that is otherwise taxable.
The proposed USMCA covers new areas such as labor, the environment, anti-corruption, and regulatory policy, among others
Three recent cases provide tips to decide if it’s worth the time and effort to appeal to the Tax Court.
A German citizen’s failure to establish that he was a resident of Germany meant he was a “covered expatriate” liable for tax on stock sale gains.
Treaties may have exceptions to saving clauses that benefit U.S. persons in terms of their U.S. income taxes.
This column discusses the portions of the act likely to affect the typical inbound real estate investment structure.
This item discusses treaty benefit limitations on U.S.-source FDAP income with respect to hybrid entities and procedural requirements of obtaining treaty benefits.
This item provides an overview of applying U.S. domestic tax law and a U.S. income tax treaty to a foreign corporation.
The meaning of the terms “amend” or “supplement” must be determined in light of the full text of a social security totalization agreement and the shared expectations of the contracting governments.
This item explains the evolution of the IRS reporting requirements for Canadian registered retirement savings plans and registered retirement income funds.
U.S. disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the IRS.
Foreign-owned disregarded entities, such as LLCs, would be required to report transactions with their owner and keep records under rules proposed by the Internal Revenue Service.
The European Commission issued two proposed directives regarding international taxation.
A taxpayer had expatriated in November 2010 when he surrendered his legal permanent resident status and therefore was subject to Sec. 877A.
The IRS has issued updated guidance on requesting and obtaining an advance pricing agreement, modifying somewhat its proposed revenue procedure published in Notice 2013-79.
Revised Procedures for Obtaining Assistance From U.S. Competent Authority, Including Discretionary Relief
The IRS published guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority.
A totalization agreement is intended to eliminate dual social taxation and to provide additional benefit protection for workers who have worked in both the United States and another country.
The United States and Switzerland announced a new protocol to allow the Swiss government to provide information to the IRS on U.S. account holders of Swiss bank UBS.