Despite a couple's ignorance of the FBAR filing requirement, their disregard of it was reckless, the Fourth Circuit holds.
Rules govern withholding on transfers and ECI.
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.
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.
Treasury’s Financial Crimes Enforcement Network briefly announced, but then rescinded, an extension of this year’s deadline to e-file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
The IRS finalized proposed regulations on withholding from transfers of partnership interests to foreign persons and the definition of effectively connected income for those purposes.
The IRS issued final and proposed regulations covering a wide variety of issues involving deductions and credits for foreign taxes.
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.
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.
The IRS announced that it will issue regulations to allow S corporations with accumulated earnings and profits to elect to have global intangible low-taxed income inclusions increase the S corporation’s accumulated adjustments account.
The IRS finalized regulations and withdrew temporary regulations on the Sec. 245A dividend rules, as well as Sec. 954 and the reporting requirements for those new rules under Sec. 6038, which were all amended by the law known as the Tax Cuts and Jobs Act.
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.
The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.
Continental shelf activities are nonexempt under the US—UK treaty, the Tax Court holds.
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.
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.
The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.
Reporting of Subpart F and GILTI inclusions may rely on 'alternate information.'
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.
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.