The IRS finalized proposed regulations issued last August on the new transition tax, which generally taxes the accumulated post-1986 deferred foreign income of a corporation.
Extended limitation period of 10 years for refund claims applies only to foreign tax credit, Second Circuit affirms.
The IRS issued proposed rules on the Sec.59A base-erosion anti-abuse tax (BEAT), one of a number of new international tax provisions added by the law known as the Tax Cuts and Jobs Act.
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.
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.
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.
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.
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.
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.
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).
Unemployment compensation received by a Canadian citizen from Ohio is subject to U.S. tax under treaty.
The draft Tax Cuts and Jobs Act makes many important changes to the tax treatment of U.S. corporations that own foreign corporations.
The passport restriction will affect the expatriate community and foreign travelers who haven’t established an agreement to pay their delinquent tax debt.
Retailer successfully defends its cost-allocation method for buy-in payments from its Luxembourg subsidiary.
The Tax Court held that Amazon.com had properly valued transfers of intangibles under a cost-sharing arrangement with its Luxembourg subsidiary.
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.
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.
Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.
Forthcoming rules will target separation of related income from foreign-initiated tax adjustments.
Practitioners must define the scope of the engagement and encourage clients to provide timely and accurate information.