International Tax News

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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IRS Falters on FATCA Compliance

Despite Huge Spending, IRS Falters on FATCA Compliance Efforts The Treasury Inspector General for Tax Administration (TIGTA) has determined that, despite spending nearly $380 million, the IRS still isn’t prepared to enforce the Foreign Account Tax Compliance Act (FATCA). TIGTA determined that the IRS has taken limited or no action on most of the planned activities…

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