International Tax News

IRS Proposes Regs on Allocation/Apportionment of Creditable Foreign Taxes

IRS Has Proposed Regs on Allocation/Apportionment of Creditable Foreign Taxes The IRS recently proposed regulations that provide guidance on the allocation and apportionment of creditable foreign taxes. The regs also cover a variety of other issues, including those related to the foreign tax credit (FTC). Allocation/Apportionment of Deductions The proposed regs address the allocation and…

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Foreign Tax Credit Final Regs

Effective Immediately: Final Regs Relating to the Foreign Tax Credit The IRS recently issued final regulations on the foreign tax credit (FTC) and other related items. The regs reflect changes made under the Tax Cuts and Jobs Act. Background on the Credit Both the United States and foreign countries may tax the foreign source income…

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Evolving FBAR Filing Verification Process

The Evolving Submission Process for FBAR Filing Verification The IRS recently changed the process under which it accepts requests for verification that it has received a filed FinCEN Form 114, “Report of Foreign Bank and Financial Accounts” (FBAR). Before November 19, 2019, the agency allowed FBAR filers to call its FBAR hotline to obtain verbal…

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IRS Relieves U.S. Shareholders of Certain Foreign Corporations

IRS Grants Relief to U.S. Shareholders of Certain Foreign Corporations The IRS recently granted relief to certain U.S. persons who own stock in certain foreign corporations affected by the repeal of Internal Revenue Code Section 958(b)(4) under the Tax Cuts and Jobs Act. Revenue Procedure 2019-40 limits the inquiries that U.S. persons must make to…

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2020 Inflation-Adjusted Figures for International Tax Items

2020 Inflation-Adjusted Figures for International Tax Items Various dollar figures related the holidays and the beginning of a new year to international tax are adjusted annually for cost-of-living increases. These adjustments reflect a measure of inflation that was revised by the Tax Cuts and Jobs Act (TCJA) called the average “chained Consumer Price Index (CPI)…

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