International tax

TOPICS / TAX

July 21, 2020

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.

July 9, 2020

FDII and GILTI regulations finalized

The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.

June 1, 2020

Chartering vessel to decommission oil and gas wells is ECI

Continental shelf activities are nonexempt under the US—UK treaty, the Tax Court holds.

May 15, 2020

IRS grants relief for COVID-19 disruptions on tax residency

Time rules are eased for the substantial presence test for foreign citizens in the US and the foreign earned income exclusion for US citizens abroad.

April 22, 2020

Relief for tax residency impacts of COVID-19 travel disruptions

Individuals and businesses can avoid having their prolonged stay in a country affect their tax residence if their cross-border travel was disrupted by the COVID-19 pandemic, under limited relief the IRS announced in two revenue procedures and FAQs.

March 20, 2020

Final regulations address covered assets acquisition rules

The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.

January 1, 2020

CFC downward attributions get safe harbors

Reporting of Subpart F and GILTI inclusions may rely on ‘alternate information.’

December 3, 2019

BEAT regs. are finalized, new regs. are proposed

The IRS issued detailed guidance on the Sec. 59A base-erosion and anti-abuse tax (BEAT), which was added to the Code by the law known as the Tax Cuts and Jobs Act.

October 1, 2019

CFC downward attributions get safe harbors

U.S. shareholders who own stock in foreign corporations were given a safe harbor by the IRS, making it easier for them to establish that they are not shareholders in a controlled foreign corporation, or CFC.

September 9, 2019

IRS offers expatriate tax relief

The IRS announced procedures to allow certain individuals who have renounced their U.S. citizenship to get into compliance with their US tax obligations and obtain relief for back taxes.

August 13, 2019

Rules proposed for classifying cloud and digital content transactions

The Internal Revenue Service proposed regulations to clarify how to classify transactions involving digital content and cloud computing.

June 19, 2019

Virtual currency not FBAR reportable (at least for now)

The AICPA Virtual Currency Task Force reached out to Treasury’s Financial Crimes Enforcement Network (FinCEN) to help practitioners answer the question of whether virtual currency (or cryptocurrency) must be reported on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

June 17, 2019

Final rules govern GILTI, Subpart F income, and foreign tax credits

The IRS issued final regulations on the Sec. 951A global low-taxed income inclusion and foreign tax credits, finalizing proposed rules issued in October and December 2018.

March 5, 2019

Guidance proposed on FDII and GILTI deductions

The IRS issued guidance on determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under Sec. 250.

January 16, 2019

Final regulations govern Sec. 965 transition tax

The IRS finalized proposed regulations issued last August on the new transition tax, which generally taxes the accumulated post-1986 deferred foreign income of a corporation.

January 1, 2019

Taxpayer’s change to foreign tax deduction is ruled untimely

Extended limitation period of 10 years for refund claims applies only to foreign tax credit, Second Circuit affirms.

December 14, 2018

Proposed regs. govern tax on base-erosion payments

The IRS issued proposed rules on the Sec.59A base-erosion anti-abuse tax (BEAT), one of a number of new international tax provisions added by the law known as the Tax Cuts and Jobs Act.

December 1, 2018

Schoolteacher’s failure to file FBAR results in $800,000 penalty

The Court of Federal Claims holds that actions and failure to inquire into reporting requirements for a foreign account by a taxpayer who had made a ‘quiet disclosure’ showed willfulness.

November 29, 2018

Proposed foreign tax credit regulations issued

The IRS issued proposed regulations on the determination of the foreign tax credit after the changes in the law made by the Tax Cuts and Jobs Act.

October 31, 2018

Proposed rules would exempt corporate US shareholders from Sec. 956

The IRS issued proposed regulations providing that Sec. 956, which requires an income inclusion by U.S. shareholders of controlled foreign corporations (CFCs) that invest in U.S. property, should not apply to corporate shareholders.

FROM THIS MONTH'S ISSUE

Flip out with the latest Tech Q&A

The September Technology Q&A column shows how to create dynamic to-do lists with Excel's checkboxes and also how to set up multifactor authentication texts that don't rely on phones. Flip through both items and view a video walkthrough in our digital format.