A district court held that the government violated a taxpayer’s Seventh Amendment right to a civil jury trial in an FBAR case.
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TOPICS / TAX
International tax
IRS announces prop. regs. on international tax law provisions in OBBBA
The proposed regulations will deal with changes included in H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act.
Managing MNE subsidiaries during tariff shocks
Multinational enterprises’ subsidiaries need other incentives to optimize their performance if transfer pricing policies guarantee them a routine profit.
Global tax deal could hurt US companies, says letter requesting OECD guidance
A letter from the Association of International Certified Professional Accountants addresses guidance and recommendations on the Pillar Two framework co-existing with U.S. tax rules for U.S. multinational enterprises in a side-by-side system to the OECD.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Foreign earned income and housing exclusion denied
Another worker at a U.S.–Australia joint defense facility fails to nullify a closing agreement waiver.
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.
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.
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.
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
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.
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