Transfer Pricing - International Updates

From Hong Kong to Peru, where you do business can have a major impact on your tax structure. Our Transfer Pricing experts work to identify where your business is at risk and provide guidance that helps… Read More »

Employee Retention Tax Credit - How to Claim the ERC

On March 27th, 2020 the CARES Act provded for the Employee Retention Credit, a refundable credit against the employer share of the Social Security tax. This was made available to recipients of PPP loans… Read More »

2020 Bank Year-End Planning

As the pandemic continues and the uncertainty of who will take control of the Senate is up in the air, major tax proposals are not anticipated immediately.    President-elect Biden’s tax proposal includes… Read More »

How Wayfair Decision Affects Your Business

While speaking at a Texas Society of CPAs’ event, I shared my view that the United States Supreme Court decision on Wayfair, giving states the power to reach across state lines and force remote businesses… Read More »

Payroll Tax Deferral - Key Considerations

Summary Employers can allow eligible employees to defer the payment of the employee portion of September 1 – December 31, 2020 Social Security Taxes into the first four months of 2021. Because this is… Read More »

IRS E-File Form 1040

E-Filing Amended Individual Tax Returns The IRS has formally followed up on an announcement from earlier this year regarding amended individual income tax returns (Form 1040).  For the first time ever,… Read More »

Eligibility to Subtract Cost of Goods Sold

Overview On April 3, 2020, the Texas Supreme Court published its opinions on 3 tax cases in connection with a taxpayer’s eligibility to subtract COGS as well as which costs are eligible to be subtracted… Read More »

Deferral of Employment Tax Deposits and Payments through December 31, 2020

On April 10, 2020, the IRS issued 11 FAQs on the deferral of employment tax deposits under the CARES Act in response to various questions that arose since the enactment of the new law. One of the most… Read More »

CARES Act Provides Favorable Changes for Taxpayers with Net Operating Loses

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provides added relief for taxpayers with net operating losses (NOLs).  The Act allows for a five-year carryback period and eliminates… Read More »

U.S. v. Schwarzbaum - FBAR Penalties

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… Read More »

IRS lists new countries with nonresident alien interest reporting requirements

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… Read More »

How Does TCJA Impact International Corporate Tax Rules?

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… Read More »

Simplifying the Rules for Reporting Income Taxes

For years, businesses have complained that the guidance under Accounting Standards Codification Topic 740, Income Taxes, includes many mechanical rules and exceptions, making it challenging for investors… Read More »

Final regs address partnership’s allocation of creditable foreign tax expenditures

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… Read More »

Taxing S corporation income otherwise allocable to nonresident alien owners of ESBTs

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… Read More »

Recognition and deferral of foreign currency gain or loss

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… Read More »

How to determine foreign-derived intangible income (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… Read More »

Proposed Regulations on the foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI)

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… Read More »

Section 965 Transition Tax Forms and Instructions

In late January, the IRS issued a series of forms and instructions regarding the Internal Revenue Code Section 965 transition tax provision, which was added by the Tax Cuts and Jobs Act. Here’s an overview… Read More »

IRS determines correct functional currency to calculate foreign currency exchange gain or loss

In a Technical Advice Memorandum (TAM) issued in February, the IRS determined which of two currencies was the correct functional currency to calculate any foreign currency exchange gain or loss under Internal… Read More »

What is Form 1118? Corporation Foreign Tax Credit Form and Instructions

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),… Read More »

IRS explains how foreign and domestic losses affect foreign tax credit

In a further indication of the IRS’s continued focus on international tax issues, the tax agency updated an International Practice Unit (IPU) summarizing the calculation and recapture of foreign and domestic… Read More »

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