International tax

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.

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.

Final and proposed regulations cover PFIC and CFC stock held through domestic partnerships and S corporations.

Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.

The IRS issued final rules on the Sec. 245A extraordinary disposition rule and the Sec. 951A disqualified basis and disqualified payment rules, as well as reporting requirements to facilitate the rules.

After a misworded posting caused confusion about the 2020 deadline to file FBARs (i.e., FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)), Treasury’s Financial Crimes Enforcement Network has extended the deadline to Oct. 31.

Treasury’s Financial Crimes Enforcement Network briefly announced, but then rescinded, an extension of this year’s deadline to e-file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

The IRS issued final and proposed regulations covering a wide variety of issues involving deductions and credits for foreign taxes.

The IRS issued final regulations on the downward attribution rules of controlled foreign corporations, whose treatment had been changed by the law known as the Tax Cuts and Jobs Act.

The IRS issued final regulations on the base-erosion and anti-abuse tax, which was created by the Tax Cuts and Jobs Act to deter attempts to shift profits to foreign jurisdictions.