International Tax News

Deadline for 2018 QI/WP/WT Agreements

IRS Reminds Certain Entities of Deadline for 2018 QI/WP/WT Agreements The IRS issued a reminder that the deadline for 2018 status applications for all Qualified Intermediary (QI) entities (including Qualified Derivatives Dealer), Withholding Foreign Partnerships (WPs) and Withholding Foreign Trusts (WTs) is November 16, 2018. This will allow sufficient time for processing by year end….

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IRS Adds to Lists of Countries with Reporting Requirements

The IRS has updated two lists of countries with which the U.S. has an agreement that requires certain payments to be reported to the United States. One list is of countries with which the United States has an income tax or other treaty or a bilateral agreement; the other is of countries with which the…

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Combat-Zone Contract Workers Income Exclusion

All Combat-Zone Contract Workers Now May Qualify for Income Exclusion U.S. citizens or resident aliens, and specifically contractors or their employees supporting the U.S. Armed Forces in combat zones, may qualify for the foreign earned income exclusion. Qualified individuals may exclude from gross income, subject to certain limitations, wages or self-employment income earned for services…

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RICs Can Defer Distributing Transition Tax Amount

RICs Can Defer Distributing Transition Tax Amount In a Revenue Procedure, the IRS has allowed regulated investment companies (RICs) to postpone to 2018 the inclusion of the Code Section 965 transition tax in gross income for purposes of computing their required distributions. RICs can be any of several financial entities, from mutual fund trade funds…

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Transfer Pricing Ruling Reversed

Appeals Court Reverses Tax Court Transfer Pricing Ruling The Court of Appeals for the Eighth Circuit vacated the U.S. Tax Court decision in a long-running and closely watched transfer pricing case involving Medtronic and its Puerto Rico subsidiary. The appeals court determined that the Tax Court had rejected the IRS’s transfer-pricing method, and adopted that…

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