International Tax News

IRS Finalizes Certain Foreign Tax Credit Regulations

IRS Finalizes Certain Foreign Tax Credit Regulations In June, the IRS finalized certain proposed regs pertaining to the foreign tax credit (FTC). The final regs include changes to the rules that address the interaction between the FTC and Internal Revenue Code (IRC) Section 965(n) rules on not applying the net operating loss deduction when calculating…

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Section 956 Update: Final Regs

Final Regs Exclude Corporate U.S. Shareholders From Application of Section 956 The IRS recently issued final regulations that reduce the amount determined under Internal Revenue Code Section 956 for certain domestic corporations that own (or are treated as owning) stock in foreign corporations. Under the regs, neither an actual dividend to a corporate U.S. shareholder,…

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District Court Refuses To Dismiss FBAR Penalty Action Against Decedent’s Family

District Court Refuses To Dismiss FBAR Penalty Action Against Decedent’s Family If you have an interest in (or authority over) a foreign financial account, you may have to electronically file a form called the “Report of Foreign Bank and Financial Accounts” (FBAR). Failing to file a required FBAR can result in penalties. In the recent…

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Proposed Regs Look To Close CFC Loopholes

The IRS recently issued proposed regs that would amend the controlled foreign corporation (CFC) related party and CFC active rent rules to close certain loopholes. Here are some details on each of the loopholes. Related Party Loophole The IRS is concerned that, in certain situations, the current rules and regs could produce inappropriate results when…

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Court Upholds Freedom of Information Act Exemption for IRS

Court Upholds Freedom of Information Act Exemption for IRS The U.S. Court of Appeals for the Federal Circuit recently handed down its decision in Agrama v. U.S. The case focused on whether the IRS satisfied its Freedom of Information Act (FOIA) burden of showing that it had conducted an adequate search for the documents that…

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