by Briggs & Veselka | Jan 31, 2019 | International Tax Newsletter
The IRS has released a new Form 1118, “Foreign Tax Credit — Corporations,” and new instructions along with it. The agency notes that, to incorporate the provisions of the Tax Cuts and Jobs Act (TCJA), extensive changes have been made to both. Credit Overview The...
by Briggs & Veselka | Jan 31, 2019 | International Tax Newsletter
The U.S. Tax Court has determined in Wentworth v. Commissioner of Internal Revenue that a taxpayer who worked for a security company in Iraq was a “qualified individual” entitled to the foreign earned income exclusion for the years at issue. Here’s a closer look at...
by Briggs & Veselka | Jan 31, 2019 | International Tax Newsletter
A U.S. district court recently held in U.S. v. Shinday, et al., that the monetary limit on the penalty for willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) is an annual one. The court found that, in reaching this conclusion, it wasn’t...
by Briggs & Veselka | Nov 20, 2018 | International Tax Newsletter
The user fee for processing residency certification made on Form 8802 (“Application for United States Residency Certification”) is increasing from $85 to $185 for nonindividual taxpayers. This is effective for forms postmarked on or after December 1, 2018. The...
by Briggs & Veselka | Nov 20, 2018 | International Tax Newsletter
In an Information Letter, the IRS has advised a taxpayer, who sold his interest in a passive foreign investment company (PFIC), on the steps to take to verify that he’d properly reported his PFIC transaction and, presumably, determine whether he’s due a refund. PFIC...
by Briggs & Veselka | Nov 20, 2018 | International Tax Newsletter
The IRS issued a reminder that the deadline for 2018 status applications for all Qualified Intermediary (QI) entities (including Qualified Derivatives Dealer), Withholding Foreign Partnerships (WPs) and Withholding Foreign Trusts (WTs) is November 16, 2018. This will...
