John Samtoy, CPA, discusses Schedules K-2 and K-3 for passthrough entities and U.S. persons who are partners in foreign partnerships, and how tax professionals can help clients with them.
International tax
Final regulations affect owners of foreign stock
Final and proposed regulations cover PFIC and CFC stock held through domestic partnerships and S corporations.
All LB&I taxpayers may videoconference with the IRS
Pandemic-inspired method for examinations and appeals meetings is extended.
Line items
SSA wage base increases for 2022 … IRS Chief Counsel outlines R&D credit refund requirements … 6-year limitation period applies to entire return
Rules for QIP under FDII and GILTI
Final regulations address calculation of qualified business asset investment.
Final regs. issued on qualified improvement property under FDII, GILTI
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.
Export tax incentives: The effect of potentially rising tax rates
U.S. exporters are evaluating how to best use IC-DISC and FDII incentives if tax rules change.
What is a global minimum tax and what will it mean?
Finance ministers for the G7 reached an agreement on Saturday supporting a global minimum tax rate of at least 15%. Here’s how it would work and what might happen next.
‘Willful’ FBAR penalties upheld
Despite a couple’s ignorance of the FBAR filing requirement, their disregard of it was reckless, the Fourth Circuit holds.
Final regs. issued on foreign partnership interests
Rules govern withholding on transfers and ECI.
Final rules coordinate Sec. 245A and Sec. 951A
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.
FBAR deadline extended to Oct. 31 after confusion
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.
FinCEN pulls announcement of extended FBAR deadline
Treasury’s Financial Crimes Enforcement Network briefly announced, but then rescinded, an extension of this year’s deadline to e-file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
Rules govern withholding on transfers of partnership interests and ECI
The IRS finalized proposed regulations on withholding from transfers of partnership interests to foreign persons and the definition of effectively connected income for those purposes.
Foreign tax credit allocation and apportionment rules finalized
The IRS issued final and proposed regulations covering a wide variety of issues involving deductions and credits for foreign taxes.
Final regs. govern CFC downward attribution
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.
Additional BEAT regs. finalized
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.
Regulations coming on S corporations with accumulated E&P and GILTI
The IRS announced that it will issue regulations to allow S corporations with accumulated earnings and profits to elect to have global intangible low-taxed income inclusions increase the S corporation’s accumulated adjustments account.
Final regs. address new dividends received deduction and reporting rules
The IRS finalized regulations and withdrew temporary regulations on the Sec. 245A dividend rules, as well as Sec. 954 and the reporting requirements for those new rules under Sec. 6038, which were all amended by the law known as the Tax Cuts and Jobs Act.
GILTI rules address income subject to high foreign tax rate
The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.
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