International Tax News

Tax Redetermination Under the Final Foreign Tax Credit Regs

Tax Redetermination Under the Final Foreign Tax Credit Regs Both the United States and foreign countries may tax the foreign source income of U.S. taxpayers. To ease this double taxation burden, the Internal Revenue Code permits most U.S. taxpayers who pay income taxes to a foreign country to either deduct the taxes from gross income…

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Self-Employed in a U.S. Territory? Prepare for IRS Scrutiny

Self-Employed in a U.S. Territory? Prepare for IRS Scrutiny The Large Business and International (LB&I) division of the IRS recently announced a new compliance campaign targeting self-employed individuals in U.S. territories who underpay or fail to pay their self-employment taxes. The self-employment tax is equal to the Social Security and Medicare taxes on net earnings…

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IRS Proposes Regs on Allocation/Apportionment of Creditable Foreign Taxes

IRS Has Proposed Regs on Allocation/Apportionment of Creditable Foreign Taxes The IRS recently proposed regulations that provide guidance on the allocation and apportionment of creditable foreign taxes. The regs also cover a variety of other issues, including those related to the foreign tax credit (FTC). Allocation/Apportionment of Deductions The proposed regs address the allocation and…

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Foreign Tax Credit Final Regs

Effective Immediately: Final Regs Relating to the Foreign Tax Credit The IRS recently issued final regulations on the foreign tax credit (FTC) and other related items. The regs reflect changes made under the Tax Cuts and Jobs Act. Background on the Credit Both the United States and foreign countries may tax the foreign source income…

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Evolving FBAR Filing Verification Process

The Evolving Submission Process for FBAR Filing Verification The IRS recently changed the process under which it accepts requests for verification that it has received a filed FinCEN Form 114, “Report of Foreign Bank and Financial Accounts” (FBAR). Before November 19, 2019, the agency allowed FBAR filers to call its FBAR hotline to obtain verbal…

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