International Tax Monthly June Issue

Coca-Cola’s Challenge to Huge Tax Bill Is Closely Watched The Coca-Cola Company is disputing a $3.3 billion tax bill related to transfer pricing. The case in U.S. Tax Court is being watched by tax experts and is considered a sign of increasing tension between tax authorities around the world and multinational corporations. According to media … Continued

International Tax Monthly April Issue

  IRS Issues Guidelines on Waiving Filing Deadlines for Foreign Corporations The IRS Large Business and International Division (LB&I) has issued guidelines for handling delinquent Forms 1120-F, U.S. Income Tax Return of a Foreign Corporation, and for making filing deadline waivers. Foreign corporations engaged in a trade or business within the U.S. can claim deductions … Continued

International Tax Monthly March Issue

IRS to Deny Certain Changes to Foreign Corporations’ Accounting Periods The IRS has modified the circumstances under which it will approve requests for changes in annual accounting periods made by certain foreign corporations in 2017. Under Revenue Procedure 2018-17, the IRS won’t approve any change to the annual accounting periods of some foreign corporations under … Continued

International Tax Monthly – February 2018 Issue

New Tax Law Includes Loophole that lets Taxpayers Trim Tax on Repatriated Income A loophole in the Tax Cuts and Jobs Act (TCJA) could allow multinational corporations like Apple to avoid paying billions of dollars in taxes on profits stashed overseas. The TCJA imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of … Continued

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