International Tax News

Foreign Tax Credit Update

IRS Explains Exhaustion of Administrative Remedies for Foreign Tax Credit In an International Practice Unit (IPU), the IRS explains how it determines that a taxpayer has exhausted administrative remedies for a foreign tax for purposes of the tax being considered creditable. Both the U.S. and foreign countries may tax the foreign source income of U.S….

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Federal Circuit Sides with Taxpayer in Extraterritorial Income Dispute

The Court of Appeals for the Federal Circuit agreed with a film production company that it was entitled to transitional relief afforded by the American Jobs Creation Act (AJCA) for extraterritorial income (ETI). The ETI was received from transactions in 2005 and 2006, including income recognized after those years. The ruling reversed and remanded for…

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Million-Dollar FBAR Penalty Stands

Supreme Court Lets Million-Dollar FBAR Penalty Stand The U.S. Supreme Court declined to review a Ninth Circuit Court of Appeals ruling that an IRS penalty imposed on a taxpayer wasn’t excessive and that the tax agency didn’t violate a treaty with Switzerland. The IRS assessed a penalty of approximately $1.2 million against the taxpayer for…

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International Tax Reform

International Tax Reform: Where Do We Stand? By: Anita Anand, JD From the time proposed legislation on tax reform was initially introduced, discussions surrounding those proposals and their impacts began and have continued since. Almost seven months after the enactment of the Tax Cuts and Jobs Act (TCJA), one would think that we would have…

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C Corporation vs. Pass-Through Entity

Should Your Business Be a C Corporation or a Pass-Through Entity? The Tax Cuts and Jobs Act (TCJA) introduced a flat 21% federal income tax rate for C corporations for tax years beginning in 2018 and beyond. Under prior law, profitable C corporations paid up to 35%. This change has caused many business owners to…

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