International tax

TOPICS / TAX

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.

October 23, 2018

Association addresses digital economy tax issues

The Association of International Certified Professional Accountants released a policy paper urging global solutions to the tax treatment of transactions in the digital economy, emphasizing its own Guiding Principles of Good Tax Policy.

September 14, 2018

IRS issues proposed regs. for GILTI inclusions

The IRS issued proposed regulations implementing Sec. 951A’s global intangible low-taxed income provision, which requires a US shareholder of a controlled foreign corporation to include this income in the shareholder’s gross income.

August 1, 2018

Proposed regs. address several transition tax issues

The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.

February 5, 2018

FinCEN announces filing deadline for 2017 FBARs

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

January 1, 2018

Canadian’s Ohio unemployment compensation is taxable

Unemployment compensation received by a Canadian citizen from Ohio is subject to U.S. tax under treaty.

November 7, 2017

Foreign income provisions in the Tax Cuts and Jobs Act

The draft Tax Cuts and Jobs Act makes many important changes to the tax treatment of U.S. corporations that own foreign corporations.

July 24, 2017

IRS heats up compliance enforcement on passport holders with tax debt

The passport restriction will affect the expatriate community and foreign travelers who haven’t established an agreement to pay their delinquent tax debt.

June 1, 2017

Amazon wins multimillion-dollar transfer-pricing dispute with IRS

Retailer successfully defends its cost-allocation method for buy-in payments from its Luxembourg subsidiary.

March 23, 2017

Amazon wins multimillion dollar transfer-pricing dispute with IRS

The Tax Court held that Amazon.com had properly valued transfers of intangibles under a cost-sharing arrangement with its Luxembourg subsidiary.

February 21, 2017

What accountants need to know about India’s demonetization

Public and management accountants in India will be busier than ever because the move is expected to bring a large portion of the population into a more institutional tax and banking system.

January 27, 2017

What repatriation tax changes could mean for U.S. companies

U.S. companies holding earnings overseas in cash could be bringing it back in response to tax reform proposed by the new administration in Washington.

December 19, 2016

FinCEN grants permanent automatic extensions for FBARs

Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.

December 1, 2016

IRS restricts more foreign tax credit splitter arrangements

Forthcoming rules will target separation of related income from foreign-initiated tax adjustments.

November 1, 2016

FBAR preparation and ethical risks

Practitioners must define the scope of the engagement and encourage clients to provide timely and accurate information.

October 14, 2016

Earnings-stripping rules make many changes from proposed regs.

The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.

October 1, 2016

No FBARs needed for player’s foreign online poker accounts

The websites had no financial purpose beyond gambling and were not financial agencies within the scope of the reporting requirement, the Ninth Circuit holds.

September 15, 2016

IRS restricts foreign tax credit splitter arrangements

The IRS issued guidance prohibiting corporations from taking foreign tax credits for taxes without repatriating the earnings to the United States.

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