The regulations would terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred to a foreign corporation
The Supreme Court held that the $10,000 maximum penalty for the nonwillful failure to file a compliant report applies on a per-report, not a per-account, basis.
The IRS announced that it will issue proposed regulations providing some relief to brokers that are required to withhold on the transfer of an interest in a publicly traded partnership (PTP) if the PTP is a foreign-traded entity.
Proposed foreign tax credit regulations provide guidance on the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery requirement, and the application of the source-based attribution requirement to withholding tax on royalty payments.
Initial plans for the Foreign Account Tax Compliance Act’s regime of reporting US taxpayers’ foreign bank accounts and other financial assets largely have stalled, the Treasury Inspector General for Tax Administration reports.
New procedures will facilitate residency certification where the Internal Revenue Service has not yet processed the applicant’s tax return.
John Samtoy, CPA, discusses Schedules K-2 and K-3 for passthrough entities and U.S. persons who are partners in foreign partnerships, and how tax professionals can help clients with them.
Final and proposed regulations cover PFIC and CFC stock held through domestic partnerships and S corporations.
SSA wage base increases for 2022 ... IRS Chief Counsel outlines R&D credit refund requirements ... 6-year limitation period applies to entire return
Pandemic-inspired method for examinations and appeals meetings is extended.
Final regulations address calculation of qualified business asset investment.
Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.
U.S. exporters are evaluating how to best use IC-DISC and FDII incentives if tax rules change.
Finance ministers for the G7 reached an agreement on Saturday supporting a global minimum tax rate of at least 15%. Here’s how it would work and what might happen next.
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.