International Tax Monthly – January 2018 Issue

New Tax Law Enacts Changes for Foreign Income and Foreign Persons The new Tax Cuts and Jobs Act (TCJA) contains many provisions affecting foreign income and business relationships with companies abroad. Here are some of the key provisions of the law. (Unless otherwise noted, the reforms apply to years starting after December 31, 2017.) Deduction … Continued

International Tax Monthly December 2017 Issue

IRS Continues Its Fusillade of Audit Campaigns The Large Business and International (LB&I) division of the IRS recently announced 11 additional issues that it will be targeting as part of its “compliance campaign” audit strategy. The IRS had previously announced 13 compliance campaigns in January of 2017. The issue-based strategy is aimed at identifying areas … Continued

International Tax Monthly – November Issue

EU Gets a New System to Resolve Double-Taxation Disputes The European Council recently approved a new system for resolving disputes between European Union (EU) nations, including disagreements related to double taxation. The new procedures are designed to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and … Continued

International Tax Monthly – October Issue

Commercial Pilot Fails Tests for Foreign Earned Income Exclusion The U.S. Tax Court has held that a commercial airline pilot stationed in South Korea failed both the “tax home” and the “bona fide residence” tests that determine whether a taxpayer qualifies for the foreign earned income exclusion. The pilot flew airplanes for Korean Air Lines … Continued

International Tax Monthly August 2017

IRS Launches CbC Reporting Pages and FAQs The IRS recently introduced its new Country-by-Country reporting website pages and published frequently asked questions related to the reports. The IRS CbC website includes a CbC reporting guidance page ( that contains links to the final CbC Treasury Regulations on filing for early reporting periods, model competent authority arrangements, … Continued

International Tax: Hybrid Mismatches, CbC Reporting, Treaty Shopping

 EU Adopts Rules to Block Hybrid Mismatching The European Commission formally adopted a directive to prevent tax avoidance through non–European Union (EU) countries. The directive is designed to neutralize the effect of hybrid mismatches, where companies try to avoid taxes by hopping from country to country to exploit differences between the tax systems of EU … Continued

International Tax Monthly: Cross-border finances, FBAR definition, Foreign tax credit

   Australia Outlines Approach to Cross-Border Financing In a long-awaited move, the Australian Taxation Office (ATO) released draft guidelines setting out its approach to cross-border related party financing arrangements. The guidance will apply to existing and new financing arrangements beginning July 1, 2017. The ATO views these arrangements as a major tax compliance risk. The … Continued

International Tax Monthly – May Issue

                OECD Issues International VAT/GST Guidelines The Organizsation for Economic Co-operation and Development (OECD) released guidelines on applying Value Added Tax (VAT) and Goods and Services Tax (GST) to international trade transactions. Officially called the Recommendation of the Council on the Application of Value Added Tax/Goods and Services Tax to the International Trade in Services … Continued

International Tax Monthly: U.S. Repatriation, EU Corporate Tax, Canadian Report

 U.S. Multinationals Optimistic for Another Repatriation Holiday President-elect Donald Trump’s election win moves Apple, Pfizer, Microsoft and other big U.S. corporations much closer than they have been in years to winning a big tax break on approximately $2.6 trillion in foreign profits. This article explains the mechanics of taxing foreign-source income, the 2004 repatriation holiday, … Continued