International tax

TOPICS / TAX

April 5, 2016

IRS’s inversion rules include earnings-stripping provisions

These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.

April 4, 2016

Panama papers leak provides road map for tax investigations

Tax authorities in various countries announced the launch of investigations after 11.5 million documents were leaked from a Panamanian law firm that specializes in setting up offshore entities.

April 1, 2016

FBAR compliance

Heightened tax compliance efforts worldwide make this a good time to review the complicated rules that apply to reporting foreign accounts on FinCEN Form 114, Report of Foreign Bank and Financial Accounts, commonly known as FBAR.

February 1, 2016

Overview of the ECI rules

This sidebar provides a brief explanation of the Internal Revenue Code’s effectively connected income (ECI) rules that may impose direct U.S. tax on certain income earned by any foreign corporation.

December 22, 2015

Proposed regulations outline country-by-country reporting requirements

The much-anticipated rules, under which the US would adopt the Organisation for Economic Co-operation and Development’s country-by-country reporting regime, would require reporting by multinational enterprise groups with revenue of $850 million or more in the prior annual accounting period.

September 9, 2015

Proposed rules govern taxation of gifts and bequests from covered expatriates

Proposed regulations under Sec. 2801 would impose a transfer tax on gifts or bequests from covered expatriates made on or after June 17, 2008.

August 1, 2015

FBAR penalty amount guidelines set

Maximum penalties for willful failure to report foreign bank accounts on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), for multiple years are limited under new IRS procedures.

July 1, 2015

IRS to limit refunds and credits of foreign withholding payments

Refunds of tax withheld under chapters 3 and 4 will be limited to the amounts actually deposited.

July 1, 2015

Transfer taxes: 5 questions to ask clients with international ties

Planning to lessen estate, gift, and generation-skipping transfer taxes increasingly requires considering clients’ foreign connections.

June 1, 2015

U.S. abode binds Russian-employed taxpayer

A taxpayer’s strong ties to the United States led to denial of the foreign earned income exclusion despite his spending half his time living and working overseas.

April 28, 2015

IRS intends to amend rules so refunds match foreign withholding payments

The IRS has proposed to amend its regulations to limit refunds paid to beneficial owners of withheld payments to amounts actually deposited by withholding agents.

April 13, 2015

Anti-splitter rules finalized

The IRS issued regulations under Sec. 909 regarding the foreign tax credit splitter rules.

March 1, 2015

Final rules govern reporting of specified foreign financial assets

The regulations provide an exception for dual-resident taxpayers taxed as residents of a treaty partner country; IRS requests comments on virtual currency.

February 9, 2015

Final rules govern foreign tax credit splitter arrangements

The IRS finalized temporary regulations issued in 2012, called anti-splitter rules because they aim to prevent foreign income from being inappropriately split from foreign tax in calculating the foreign tax credit.

January 28, 2015

Offshore Voluntary Disclosure Program to remain open indefinitely

The IRS stated that it intends to keep its Offshore Voluntary Disclosure Program open until it announces otherwise.

December 11, 2014

Final rules govern reporting of specified foreign financial assets

Final regulations issued on Thursday explain how taxpayers whose specified foreign financial assets are great enough to trigger the Sec. 6038D reporting requirement can comply with the rules.

December 1, 2014

Tax phishing goes global with FATCA

Scam artists impersonating the IRS have been requesting foreign financial account holders’ personal and account information, the IRS warned in a news release.

December 1, 2014

IRS puts would-be corporate inverters on notice

Coming regulations will reduce tax benefits of inversions by preventing certain uses of controlled foreign corporations and closing loopholes in the Sec. 7874 anti-inversion provisions.

October 13, 2014

Changes made to IRS streamlined offshore compliance procedures

The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed

October 13, 2014

Certain FATCA deadlines are postponed

The IRS announced its intention in Notice 2014-59 to amend temporary regulations it issued under the Foreign Account Tax Compliance Act (FATCA) on March 6, 2014, to modify the effective dates of (1) the standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee