International Tax News

Section 965 Transition Tax Forms and Instructions Now Available

Section 965 Transition Tax Forms and Instructions Now Available In late January, the IRS issued a series of forms and instructions regarding the Internal Revenue Code Section 965 transition tax provision, which was added by the Tax Cuts and Jobs Act. Here’s an overview of the pertinent paperwork. Primary Requirements Sec. 965 generally requires U.S….

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IRS Determines Correct Functional Currency To Calculate Foreign Currency Exchange Gain or Loss

IRS Determines Correct Functional Currency To Calculate Foreign Currency Exchange Gain or Loss In a Technical Advice Memorandum (TAM) issued in February, the IRS determined which of two currencies was the correct functional currency to calculate any foreign currency exchange gain or loss under Internal Revenue Code Section 988. The TAM revolved around payments of…

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Tax Court Thwarts Use of Rule 155

Tax Court Thwarts Use of Rule 155 to Raise New Issues In Vento et al., a case decided in February, the U.S. Tax Court has held that the taxpayers involved couldn’t use Tax Court Rule 155 to raise new issues in litigation where they were denied foreign tax credits under Internal Revenue Code Section 901…

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I-9 Audits On the Rise

I-9 Audits Are On the Rise: Be Prepared I-9 audits quadrupled in 2018 over the prior year (the federal fiscal year). That means nearly 6,000 employers were audited, which led to several dozen civil and criminal convictions. The agency involved — Homeland Security Investigations (HSI) — “is carrying out its commitment to increase the number…

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Finalized Section 965 Transition Regs: Adjustments to E&P and Basis

Finalized Section 965 Transition Regs: Adjustments to E&P and Basis The IRS has issued highly anticipated final regulations under Internal Revenue Code Section 965, the transition tax provision added by the Tax Cuts and Jobs Act. Sec. 965 generally requires U.S. shareholders to pay a “transition tax” on the untaxed foreign earnings of certain specified…

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