International Tax Monthly

In a Revenue Procedure, the IRS has allowed regulated investment companies (RICs) to postpone to 2018 the inclusion of the Code Section 965 transition tax in gross income for purposes of computing their required distributions. RICs can be any of several financial entities, from mutual fund trade funds to real estate investment rusts or unit … Continued

U.S. citizens or resident aliens, and specifically contractors or their employees supporting the U.S. Armed Forces in combat zones, may qualify for the foreign earned income exclusion.  Qualified individuals may exclude from gross income, subject to certain limitations, wages or self-employment income earned for services performed outside the United States. To be entitled, however, a … Continued

If your answer is yes, you have a minimum requirement to file Form 8858. The amount of your involvement is a deciding factor for the requirement of filing additional forms such as Schedules C, H and M, to list a few. Form 8858 is a common form missed by many taxpayers year after year and … Continued

The IRS has updated two lists of countries with which the U.S. has an agreement that requires certain payments to be reported to the United States. One list is of countries with which the United States has an income tax or other treaty or a bilateral agreement; the other is of countries with which the … Continued

Coming to the opposite conclusion reached by two district courts, the U.S. Court of Federal Claims has held that a reg is invalid if it doesn’t reflect a statutory increase in the penalty for willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR). The court also determined that a taxpayer’s failure … Continued

The IRS has revised its frequently asked questions (FAQs) on Qualified Intermediaries (QIs), Withholding Foreign Partnerships (WPs), and Withholding Foreign Trusts (WTs), in relation to the Foreign Account Tax Compliance Act (FATCA). The changes are aimed at providing guidance on a QI’s obligations under the 2017 and 2014 QI Agreements with respect to certain tax-free … Continued

IRS Finalizes Regs that Close Corporate Inversion Loopholes Basically, corporate inversions (also called “expatriation transactions”) generally involve a U.S. corporation engaging in a series of transactions with the effect of moving its headquarters from the U.S. to a lower-taxed foreign jurisdiction. The transactions might be affected in two ways: 1.By the U.S. corporation becoming a … Continued