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.
International tax
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.
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).
Canadian’s Ohio unemployment compensation is taxable
Unemployment compensation received by a Canadian citizen from Ohio is subject to U.S. tax under treaty.
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.
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.
Amazon wins multimillion-dollar transfer-pricing dispute with IRS
Retailer successfully defends its cost-allocation method for buy-in payments from its Luxembourg subsidiary.
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.
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.
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.
FinCEN grants permanent automatic extensions for FBARs
Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.
IRS restricts more foreign tax credit splitter arrangements
Forthcoming rules will target separation of related income from foreign-initiated tax adjustments.
FBAR preparation and ethical risks
Practitioners must define the scope of the engagement and encourage clients to provide timely and accurate information.
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.
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.
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.
VATs/GSTs continue to increase worldwide
Overseas nations strapped for cash are turning to indirect taxes.
Final rules govern U.S. country-by-country reporting
The IRS issued final regulations requiring the ultimate parent entity of a multinational enterprise group with revenue of $850 million or more in the preceding accounting period to file Form 8975, Country-by-Country Report.
Updating VAT rules to reflect the 21st century economy
Many jurisdictions around the world are amending their rules to keep up with technological advances and the rise of new business models.
Amended rules govern FIRPTA dispositions
Guidance is issued on PATH Act amendments.
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