International tax

TOPICS / TAX

August 1, 2025

Eleventh Circuit finds some FBAR penalties are excessive

The appeals court held that some of a taxpayer’s FBAR penalties were disproportional to the offense and thus an excessive fine under the Eighth Amendment.

June 16, 2025

AICPA makes Priority Guidance Plan recommendations to IRS

In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.

June 11, 2025

Appeals court leaves tariffs in place, seeks expedited argument schedule

A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.

May 9, 2025

Are you aware of this May 30, 2025, filing deadline?

If you have a client that owns at least 10% of a foreign enterprise, they must file forms for the BE-10 survey.

March 1, 2025

FBAR penalties are not taxes imposed by the Code

Because they are imposed under Title 31, taxpayers’ foreign bank account reporting failure penalties were not subject to the Code’s procedural requirements, the Tax Court held.

February 1, 2025

FBAR penalties are not extinguished upon taxpayer’s death

FBAR penalties accrue on the date the FBAR form is due, not the date the penalty is assessed, a district court held.

November 11, 2024

CRFB leader: Tax policy may not be a Trump administration high priority

The head of the nonpartisan Committee for a Responsible Federal Budget told the AICPA & CIMA National Tax Conference that extending the Tax Cuts and Jobs Act would add $5 trillion to the national debt.

August 1, 2024

D.C. Circuit reverses Tax Court on assessment of foreign entity ownership reporting penalties

The penalties under Sec. 6038(b) are administratively assessable by the IRS despite not being so designated, the appellate court holds.

June 20, 2024

Supreme Court issues narrow opinion upholding Sec. 965 transition tax

The Supreme Court upheld the mandatory repatriation tax as a valid exercise of Congress’s taxing authority. The Court did not reach the question of whether income must be realized to be taxable.

May 8, 2024

Foreign trust transactions and large gifts addressed in proposed regs.

The proposed regulations implement Secs. 643(i), 679, 6039F, 6048, and 6677, which were added or modified to prevent efforts by U.S. taxpayers to use foreign trusts and offshore arrangements to avoid U.S. taxes.

April 1, 2024

Foreign earned income and housing exclusion denied

Another worker at a U.S.–Australia joint defense facility fails to nullify a closing agreement waiver.

December 6, 2023

Supreme Court hears arguments in challenge to Sec. 965 transition tax

At stake is up to $340 billion in tax revenue in case where couple is challenging tax that they say increased their liability by about $15,000 in 2017.

November 1, 2023

US Supreme Court will hear repatriation tax challenge

Taxpayers are appealing a Ninth Circuit holding that the tax does not violate the US Constitution’s Apportionment Clause or the Fifth Amendment’s Due Process Clause.

July 1, 2023

Mitigating risk of large FBAR and international tax claims

Claims relating to U.S. filing obligations for foreign activity, including the FBAR, are getting increasingly more severe.

May 2, 2023

Proposed regs. provide rules for repatriation of intangible property

The regulations would terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred to a foreign corporation

February 28, 2023

Supreme Court holds FBAR penalty is imposed per report, not per account

The Supreme Court held that the $10,000 maximum penalty for the nonwillful failure to file a compliant report applies on a per-report, not a per-account, basis.

December 21, 2022

Prop. regs. to provide withholding relief on sales of foreign PTPs

The IRS announced that it will issue proposed regulations providing some relief to brokers that are required to withhold on the transfer of an interest in a publicly traded partnership (PTP) if the PTP is a foreign-traded entity.

November 22, 2022

Proposed regulations provide guidance on foreign tax credit rules

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.

April 13, 2022

IRS’s FATCA enforcement fell short, TIGTA says

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.

April 5, 2022