International tax

Certain FATCA deadlines are postponed

The IRS announced its intention in Notice 2014-59 to amend temporary regulations it issued under the Foreign Account Tax Compliance Act (FATCA) on March 6, 2014, to modify the effective dates of (1) the standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee

Changes made to IRS streamlined offshore compliance procedures

The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed

PFIC reporting rules do not apply to certain marked-to-market stock

On Wednesday, the IRS announced that it will amend the regulations governing the reporting requirements for U.S. persons who hold stock in passive foreign investment companies (PFICs). The amendments will provide that, if a taxpayer marks to market PFIC stock under Sec. 475 or any Code section other than Sec.

Country-by-country reporting by multinationals

The Organisation for Economic Co-operation and Development (OECD) has recently been advocating for increased tax transparency and for international cooperation to prevent tax avoidance. One element of this international cooperation that the OECD would like to see implemented is country-by-country income and tax reporting by multinational corporations. Country-by-country reporting would

Accounting across borders

CPA firms are finding international services a booming business, based on responses to a recent AICPA Private Companies Practice Section (PCPS) survey. The survey examines practitioners’ interest in expanding to new markets and growing an international clientele, as well as firms’ top international challenges and needs.

Final FATCA rules are issued

On Thursday, the IRS released a large package of regulations needed to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147, requires U.S. withholding agents to withhold tax on certain payments to foreign financial institutions

Swiss court stops handover of tax information to U.S.

A Swiss court has prevented the handover of information on U.S. account holders to the IRS by the Julius Baer Group Ltd., a Swiss bank (A v. Federal Tax Administration, A-5390/2013 (Fed. Admin. Ct. 1/6/14)). The IRS requested information from the bank on its customers who are U.S. citizens based

Six more countries sign FATCA agreements with U.S.

The Treasury Department announced on Thursday that the United States has signed six more bilateral agreements to implement the reporting and withholding provisions of the Foreign Account Tax Compliance Act (FATCA), P.L. 111-147. The agreements with the Netherlands, Malta, Bermuda, Jersey, Guernsey, and the Isle of Man bring the number

What to do when a client has an undisclosed foreign account

CPAs often have clients with an interest in or signature authority over a foreign account. The IRS has emphasized compliance in reporting requirements for U.S. owners of foreign accounts, but many taxpayers may still not know their responsibilities and liabilities. This article outlines these responsibilities and liabilities and describes current

Guidance issued for FFIs with FATCA agreements

On Tuesday, the IRS issued its latest guidance in preparation for the implementation of the Foreign Account Tax Compliance Act (FATCA) reporting and withholding requirements (Notice 2013-69). The guidance applies to foreign financial institutions (FFIs) entering into an FFI agreement with the IRS under Sec. 1471 or to FFIs or

Final regulations attack artificially generated foreign tax credits

The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit (T.D. 9634). The regulations are designed to curb certain transactions that the IRS says “produce inappropriate foreign tax credit results.” They finalize proposed regulations issued in 2011 with no substantive change

Online FATCA registration system launched

The IRS on Monday announced the launch of an online system that foreign financial institutions (FFIs) can use to register with the agency to meet their obligations under the Foreign Account Tax Compliance Act (FATCA) (IR-2013-69 (8/19/13)). The system allows institutions that must register with the IRS to create an

IRS issues draft FATCA report form

On Thursday, the IRS released a draft Form 8966, FATCA Report, which will be used by foreign financial institutions (FFIs) and withholding agents to comply with their FATCA reporting and withholding requirements. Under the Foreign Account Tax Compliance Act (FATCA), enacted as part of the Hiring Incentives to Restore Employment

Supreme Court resolves circuit split on creditability of U.K. tax

In a unanimous decision, the U.S. Supreme Court held that the United Kingdom’s windfall profits tax imposed on newly privatized businesses was creditable against U.S. taxes under Sec. 901 (PPL Corp., No.12-43 (U.S. 5/20/13)). In doing so, the Court reversed the Third Circuit’s decision (665 F.3d 60 (3d Cir. 2011))

FATCA deadlines are postponed for six months

On Friday, the IRS said it was delaying for six months some of the deadlines for implementing the Foreign Account Tax Compliance Act (FATCA) originally set out in the final regulations issued in April in T.D. 9610 (Notice 2013-43). The regulations, which provide rules on information reporting by foreign financial

GAO: Foreign account “quiet disclosures” may be much higher than detected

More than 10,000 taxpayers showed signs of having avoided offshore penalties by making “quiet disclosures” of foreign bank accounts for tax years 2003 through 2008, the U.S. Government Accountability Office (GAO) reported, a period for which the IRS has detected several hundred quiet disclosures. Filing data also suggest many more

Indoor tanning tax final regulations issued

On Monday, the IRS issued final regulations on the 10% excise tax that has been in effect for amounts paid for indoor tanning services since July 1, 2010 (T.D. 9621). The regulations, which apply to amounts paid on or after June 11, 2013, finalize proposed rules issued in 2010 when

Supreme Court resolves circuit split on creditability of U.K. tax

In a unanimous decision, the U.S. Supreme Court held that the United Kingdom’s windfall profits tax imposed on newly privatized businesses was creditable against U.S. taxes under Sec. 901 (PPL Corp., No.12-43 (U.S. 5/20/13)). In doing so, the Court reversed the Third Circuit’s decision (665 F.3d 60 (3d Cir. 2011))

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