Oct 28, 2019 | International Tax Newsletter
In U.S. v. Schwarzbaum, a federal district court recently rejected an individual’s claims that penalties assessed against him for failing to file multiple Reports of Foreign Bank and Financial Accounts (FBARs) should be set aside. He argued that they were assessed...
Oct 28, 2019 | International Tax Newsletter
In a recent revenue procedure, the IRS updated two lists of countries with which the United States has agreements that require payers to report certain deposit interest paid to nonresident alien individuals who are residents of the other country. One list is of...
Oct 28, 2019 | International Tax Newsletter
The Congressional Research Service recently issued a report that looks at how changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to international corporate tax rules addressed concerns under previous tax law. The report also points out problems, issues and legal...
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...
