A new version of Form 8854, Expatriation Information Statement, and new instructions were posted on the IRS Web site on May 14. The form expands the previous Form 8854 into parts A and B, with part B aimed at those new to the expatriation regime. The IRS has also issued
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TOPICS / TAX
International tax
Administration’s International Tax Proposals Plan to Raise $210B Over 10 Years
President Obama released his plan to raise $198.3 billion from 2011–2019 by overhauling international taxes, which will affect multinational corporations. When combined with further international tax reforms that will be described in the administration’s full budget proposal, the proposed international tax reform package would raise $210 billion over the next
International Tax Provisions Introduced and to Be Considered This Year
President Obama’s budget proposal for the 2010 fiscal year includes “certain international tax reform and enforcement measures,” but the only detail on this is the following one-line item from the associated revenue table: “implement international enforcement, reform deferral, and other tax reform policies.” This is estimated to raise $210 billion
New Regs Govern Overseas Disclosure and Use of Taxpayer Information
Editor’s note: This article appears in the February 2009 issue of The Tax Adviser, the AICPA’s monthly journal of tax planning, trends and techniques. Sec. 7216 and the regulations thereunder were promulgated to set guidelines and impose restrictions on the use and disclosure of taxpayer information by tax return
Withholding From Foreign Payments: IRM Section Offers Insight
CPAs with clients whose responsibilities include withholding and remitting taxes on payments to foreign individuals and entities can help those clients understand guidelines and institute sound practices. Often, these “withholding agents” are financial institutions, but they can include any individual, business or other entity paying U.S.- source income to a
Congress Passes Expat Rules
Just before the Memorial Day holiday, the U.S. House and Senate passed by unanimous consent and voice vote, respectively, HR 6081, the Heroes Earnings Assistance and Relief Tax Act. The act provides benefits to military personnel, funded in part by new rules for taxing individuals who expatriate. The bill also
The Scholarship Trap for Foreign Students
Many U.S. colleges and universities recruit foreign students, especially for graduate programs and athletics. Such students often receive full scholarships that include room and board, making them subject to U.S. income taxes. These students may be unfamiliar with the U.S. tax system, but they need to understand
How Will IFRS Affect Tax Practitioners?
M any companies are in the early stages of considering what impact the transition to International Financial Reporting Standards (IFRS) from U.S. GAAP will have on financial reporting. However, are they also thinking about the impact it will have on tax reporting? While practitioners may have focused on the
The Liechtenstein Connection
The IRS warned that some 100 Americans were likely to be caught up in its investigation in cooperation with other countries of tax evasion in Liechtenstein. Any U.S. taxpayer hiding income and gains in the tiny principality in the European Alps would do well to “make a prompt and complete
Third Circuit Silences National Muffler, Pumps Chevron Deference
The Third Circuit Court of Appeals recently upheld the validity of Treas. Reg. § 1.882-4(a)(3)(i), which disallows deductions by a foreign corporation that fails to file a U.S. tax return within 18 months of the normal due date. When assessing the validity of the regulation, the Third Circuit applied the
IRS Can’t Shake Yardstick at Tax Treaty
The Court of Appeals for the Federal Circuit ruled a U.K. bank was entitled to a $65 million refund because the IRS applied a regulation that increased the institution’s income by $155 million in violation of the U.S.-U.K. tax treaty of 1975. In the tax years 1981–1987, National Westminster Bank
Highlights
FASB issued Statement no. 141(R), Business Combinations , and Statement no. 160, Noncontrolling Interests in Consolidated Financial Statements . Effective for fiscal years beginning after Dec. 15, 2008, the standards are intended to improve, simplify and internationally converge accounting for business combinations and the reporting of noncontrolling interests
Auditing
For news from the AICPA and state societies, visit www.cpa2biz.com, which also offers online CPE, AICPA professional literature, practice management aids and links to state society Web sites. The findings were based on inspections conducted between 2004 and 2006. The PCAOB released a report on the deficiencies to help
Highlights
The Center for Audit Quality issued a set of white papers to address issues practitioners may encounter as a result of the “liquidity crisis” spurred by deterioration in the markets for subprime mortgages and related securities. The CAQ Professional Practice Executive Committee said firms would benefit from the
Banking
For news from the AICPA and state societies, visit www.cpa2biz.com, which also offers online CPE, AICPA professional literature, practice management aids and links to state society Web sites. Loan-loss provisions totaled $11.4 billion in the quarter, a 75.3% increase from the year-ago period. The value of loans and leases
Foreign Tax Credit Form Revised
The IRS is requesting comments to proposed changes to Form 1118, Foreign Tax Credit—Corporations . U.S. corporate taxpayers use the form to compute the foreign tax credit for certain taxes paid or accrued to foreign countries or U.S. possessions. As noted in IRS Announcement 2007-62; 2007-29 IRB 1, the changes
AICPA Criticizes Foreign Currency Regs
Proposed regulations amending IRC section 987 may frustrate the intent of the Tax Reform Act of 1986 and place an undue burden on taxpayers, the AICPA said. The new regulations establish a “foreign exchange exposure pool” method of reporting gain and loss transacted in a foreign currency. Comments developed by
IFRS: Coming to America
EXECUTIVE SUMMARY International Financial Reporting Standards (IFRS) are destined to be the lingua franca of the international accounting world. Approximately 100 countries already require, allow or are in the process of converging their national accounting standards with IFRS. FASB and the IASB have agreed to converge
Taxing International Transactions: A World of Difference
Globalization has brought many new opportunities for U.S. businesses. By pursuing broader horizons, however, your clients can find themselves in unfamiliar shoals of the tax code. Here are 10 of the leading situations in which clients might need help navigating through international transactions. A “person,” in these
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