May 21, 2019 | International Tax Newsletter
In a recent Revenue Procedure, the IRS waived the residency and presence tests that apply for purposes of the foreign earned income and foreign housing cost exclusions under the tax code. Specifically, the waivers apply to certain U.S. individuals in the Democratic...
May 21, 2019 | International Tax Newsletter
The U.S. Court of Appeals for the Fifth Circuit recently handed down a decision in Tucker v. Comm., a case involving foreign currency options. In it, the appellate court affirmed the U.S. Tax Court’s position that a complex offsetting foreign currency option...
May 21, 2019 | International Tax Newsletter
The IRS recently issued final regulations under the Internal Revenue Code regarding the Foreign Account Tax Compliance Act (FATCA). The final regs provide compliance requirements and verification procedures for sponsoring entities of foreign financial institutions...
Apr 22, 2019 | International Tax Newsletter
Court defines “financial interest” and makes other FBAR rulings In U.S. v. Horowitz, a district court ruled on various issues regarding the Report of Foreign Bank and Financial Accounts (FBAR). Its decision, handed down in January, addressed the statute of limitations...
Apr 22, 2019 | International Tax Newsletter
Deep dive on proposed regs for how to determine FDII In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate...
Apr 22, 2019 | International Tax Newsletter
An overview of the proposed regs on the FDII and GILTI deduction In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also...
