International Tax News

FBAR Penalty Not Time-Barred

In the Courts: Individual’s FBAR Penalty Not Time-Barred In U.S. v. Schwarzbaum, a federal district court recently rejected an individual’s claims that penalties assessed against him for failing to file multiple Reports of Foreign Bank and Financial Accounts (FBARs) should be set aside. He argued that they were assessed after the limitations period had expired. The…

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Report: TCJA Impacts International Corporate Tax Rules

Report Addresses TCJA Impact on International Corporate Tax Rules The Congressional Research Service recently issued a report that looks at how changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to international corporate tax rules addressed concerns under previous tax law. The report also points out problems, issues and legal uncertainties that…

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IRS Updates Countries With Nonresident Alien Interest Reporting Requirements

IRS Updates Lists of Countries With Nonresident Alien Interest Reporting Requirements In a recent revenue procedure, the IRS updated two lists of countries with which the United States has agreements that require payers to report certain deposit interest paid to nonresident alien individuals who are residents of the other country. One list is of countries…

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IRS Will Allow Foreign Tax Credit for Previously Noncreditable French Taxes

IRS Will Allow Foreign Tax Credit for Previously Noncreditable French Taxes The IRS has issued a statement saying it will no longer challenge claims for foreign tax credits (FTCs) related to the French Contribution Sociale Généralisée (CSG) and Contribution au Remboursement de la Dette Sociale (CRDS) taxes. Let’s take a closer look. Statutory Rules Internal…

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FATCA: Explanations of Key Certifications and Periodic Review Requirements

FATCA: Explanations of Key Certifications and Periodic Review Requirements The IRS has revised its general frequently asked questions (FAQs) on the Foreign Account Tax Compliance Act (FATCA). The revisions focus on certification and periodic review requirements involving Qualified Intermediaries (QIs), Withholding Foreign Partnerships (WPs) and Withholding Foreign Trusts (WTs). Here are the pertinent changes: FAQ…

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