Sep 12, 2019 | International Tax Newsletter
In January 2017, the IRS announced a new audit strategy for its Large Business and International (LB&I) Division known as “campaigns.” With the campaigns, LB&I essentially shifts its examinations based on compliance issues that the Division determines present...
Sep 12, 2019 | International Tax Newsletter
The IRS recently issued questions and answers (Q&As) regarding the transition tax imposed by Internal Revenue Code Section 965. Under finalized regs issued early in 2019, Sec. 965 generally requires U.S. shareholders to pay a “transition tax” on the untaxed...
Sep 12, 2019 | International Tax Newsletter
The IRS recently issued final regulations on the operation of a safe harbor rule that’s used in determining whether allocations of partnership creditable foreign tax expenditures (CFTEs) to partners are deemed to be in accordance with the partners’ interests in the...
Jul 23, 2019 | International Tax Newsletter
The IRS recently issued proposed regulations that would amend the controlled foreign corporation (CFC) related party and CFC active rent rules to close certain loopholes. Here are some details on each of the loopholes. Related party loophole The IRS is concerned that,...
Jul 23, 2019 | International Tax Newsletter
The IRS recently issued final regulations that reduce the amount determined under Internal Revenue Code Section 956 for certain domestic corporations that own (or are treated as owning) stock in foreign corporations. Under the regs, neither an actual dividend to a...
Jul 23, 2019 | International Tax Newsletter
If you hold an interest in (or authority over) a foreign financial account, you may have to electronically file a form called the “Report of Foreign Bank and Financial Accounts” (FBAR). Failing to file a required FBAR can result in penalties. In the recent case of...
