International Tax News

Combat-Zone Contract Workers Income Exclusion

All Combat-Zone Contract Workers Now May Qualify for Income Exclusion 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…

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RICs Can Defer Distributing Transition Tax Amount

RICs Can Defer Distributing Transition Tax Amount 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…

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Transfer Pricing Ruling Reversed

Appeals Court Reverses Tax Court Transfer Pricing Ruling The Court of Appeals for the Eighth Circuit vacated the U.S. Tax Court decision in a long-running and closely watched transfer pricing case involving Medtronic and its Puerto Rico subsidiary. The appeals court determined that the Tax Court had rejected the IRS’s transfer-pricing method, and adopted that…

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Foreign Tax-Free Savings Accounts Obligations

IRS Explains Intermediaries’ Obligations on Foreign Tax-Free Savings Accounts 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…

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FBAR Willful Failure Reg Ruled Invalid

Federal Claims Court Rules FBAR Willful Failure Reg Is Invalid 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…

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