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TOPICS / TAX

Grappling with Schedules K-2 and K-3

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.

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SSA wage base increases for 2022 … IRS Chief Counsel outlines R&D credit refund requirements … 6-year limitation period applies to entire return

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Treasury’s Financial Crimes Enforcement Network briefly announced, but then rescinded, an extension of this year’s deadline to e-file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

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.

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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