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.
The IRS announced procedures to allow certain individuals who have renounced their U.S. citizenship to get into compliance with their US tax obligations and obtain relief for back taxes.
The Internal Revenue Service proposed regulations to clarify how to classify transactions involving digital content and cloud computing.
The AICPA Virtual Currency Task Force reached out to Treasury’s Financial Crimes Enforcement Network (FinCEN) to help practitioners answer the question of whether virtual currency (or cryptocurrency) must be reported on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
The IRS issued final regulations on the Sec. 951A global low-taxed income inclusion and foreign tax credits, finalizing proposed rules issued in October and December 2018.
The IRS issued guidance on determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under Sec. 250.
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.