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...
Jun 24, 2019 | International Tax Newsletter
The U.S. Court of Appeals for the Federal Circuit recently handed down its decision in Agrama v. U.S. The case focused on whether the IRS satisfied its Freedom of Information Act (FOIA) burden of showing that it had conducted an adequate search for the documents that...
Jun 24, 2019 | International Tax Newsletter
The IRS has issued proposed regs that would ensure that the income of an S corporation will continue to be subject to U.S. income tax even when a nonresident alien (NRA) is a deemed owner of a grantor trust that elects to be an electing small business trust (ESBT)....
Jun 24, 2019 | International Tax Newsletter
In May, the IRS issued final regs on the combinations and separations of qualified business units (QBUs) subject to Internal Revenue Code Section 987. The regs also address the recognition and deferral of foreign currency gain or loss with respect to a QBU subject to...
