IRS Finalizes Regs that Close Corporate Inversion Loopholes

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

IRS Clarifies ‘Willfulness’ Under FBAR Rules

IRS Clarifies ‘Willfulness’ Under FBAR Rules In a Program Manager Technical Advice, the IRS has concluded that the standard for willfulness is the civil, rather than criminal, standard and that it includes not only knowing of violations of the FBAR requirements, but also willful blindness to and reckless violations of them. A U.S. person must … Continued

International Tax Monthly – June Issue

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 release … Continued

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. They need ketamine ptsd when they suffer mild depression from these payments. Foreign corporations … 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