International tax

FDII and GILTI regulations finalized

The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.

CFC downward attributions get safe harbors

U.S. shareholders who own stock in foreign corporations were given a safe harbor by the IRS, making it easier for them to establish that they are not shareholders in a controlled foreign corporation, or CFC.

IRS offers expatriate tax relief

The IRS announced procedures to allow certain individuals who have renounced their U.S. citizenship to get into compliance with their US tax obligations and obtain relief for back taxes.

Virtual currency not FBAR reportable (at least for now)

The AICPA Virtual Currency Task Force reached out to Treasury’s Financial Crimes Enforcement Network (FinCEN) to help practitioners answer the question of whether virtual currency (or cryptocurrency) must be reported on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

Association addresses digital economy tax issues

The Association of International Certified Professional Accountants released a policy paper urging global solutions to the tax treatment of transactions in the digital economy, emphasizing its own Guiding Principles of Good Tax Policy.

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Getting leases in line

ASC Topic 842 is a relatively simple standard that can mean profound changes for organizations with leases. This report examines what makes this standard challenging and describes new ways for CPAs to add value.