International Tax News

Offsetting Foreign Currency Option Transaction Had No Economic Substance

Offsetting Foreign Currency Option Transaction Had No Economic Substance The U.S. Court of Appeals for the Fifth Circuit recently handed down a decision in Tucker v. Comm., a case involving foreign currency options. In it, the appellate court affirmed the U.S. Tax Court’s position that a complex offsetting foreign currency option transaction had no economic…

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IRS Finalizes FATCA Regs on Requirements for Sponsoring Entities

IRS Finalizes FATCA Regs on Requirements for Sponsoring Entities The IRS recently issued final regulations under the Internal Revenue Code regarding the Foreign Account Tax Compliance Act (FATCA). The final regs provide compliance requirements and verification procedures for sponsoring entities of foreign financial institutions (FFIs) and certain nonfinancial foreign entities (NFFEs). They also explain the:…

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Court Makes FBAR Rulings

Court Defines “Financial Interest” and Makes Other FBAR Rulings In U.S. v. Horowitz, a district court ruled on various issues regarding the Report of Foreign Bank and Financial Accounts (FBAR). Its decision, handed down in January, addressed the statute of limitations for assessing FBAR penalties and the definitions of various FBAR terms, including the term…

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Proposed Regs to Determine FDII

Proposed Regs Set Out How to Determine FDII In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. In this article, we’ll review what led to…

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Proposed Regs on the FDII and GILTI Deduction

An Overview of the Proposed Regs on the FDII and GILTI Deduction In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. Here’s an overview. Background…

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