International Tax News

High Court Refuses to Review Bank’s Foreign Tax Credits

The Supreme Court declined to review an appeals court ruling that the “trust” component of a Structured Trust Advantaged Repackaged Securities (STARS) transaction lacked economic substance. Background: The U.S. Court of Appeals for the First Circuit had found that the trust transaction, which involved the participating bank transferring assets to a disregarded foreign trust and…

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Anti-Injunction Act Blocks Efforts for More Lenient Tax Treatment

The U.S. Court of Appeals for the District of Columbia Circuit, affirming a district court, has concluded that the Anti-Injunction Act barred the suit of taxpayers who didn’t meet the requirements of a streamlined compliance program but who nonetheless sought to have the court allow them to participate in that program. The voluntary program was…

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IRS Launches CbC Reporting Pages and FAQs

The IRS recently introduced its new Country-by-Country reporting website pages and published frequently asked questions related to the reports. The IRS CbC website includes a CbC reporting guidance page that contains links to the final CbC Treasury Regulations on filing for early reporting periods, model competent authority arrangements, OECD guidance, and forms and instructions. CbC…

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Returned Tax Payments Were Refunds for Purposes of Foreign Tax Credit

The Tax Court ruled that certain payments received by a U.S. citizen working abroad from a foreign taxing authority were in fact refunds under the Internal Revenue Code. Facts of the Case A U.S. citizen worked for the London office of Goldman Sachs and received employee compensation from which United Kingdom income tax was withheld….

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District Court: Definition of ‘Willful’ is Unclear in FBAR Case

The U.S. District Court for the Eastern District of Pennsylvania denied summary judgment to both the IRS and a taxpayer with regard to his Swiss bank account. In the case, the tax agency slapped the maximum penalty on the taxpayer for willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR). The…

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