International Tax News

Limit on FBAR Willful Violation Penalty Applies Annually

Limit on FBAR Willful Violation Penalty Applies Annually A U.S. district court recently held in U.S. vs. Shinday, et al., that the monetary limit on the penalty for willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) is an annual one. The court found that, in reaching this conclusion, it wasn’t…

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Corporation Foreign Tax Credit Form and Instructions

IRS Releases Corporation Foreign Tax Credit Form and Instructions The IRS has released a new Form 1118, “Foreign Tax Credit—Corporations” and new instructions along with it. The agency notes that, to incorporate the provisions of the Tax Cuts and Jobs Act (TCJA), extensive changes have been made to both. Credit Overview The United States, its…

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Deductions and Work-Travel Programs

Foreign Students Can’t Deduct Travel Costs of Work-Travel Program The U.S. Court of Appeals for the District of Columbia Circuit, affirming the U.S. Tax Court, has held that foreign students who traveled to the United States as part of a work-travel exchange program couldn’t deduct their travel costs. Seasonal or Temporary Jobs Three students in…

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Earned Income Exclusion Disqualification

Military Contractor in Afghanistan Didn’t Qualify for Earned Income Exclusion The U.S. Tax Court has held that an aircraft captain for a military contractor wasn’t entitled to exclude income that he earned working in Afghanistan. It found that for tax purposes, his “abode” was within the U.S. during his deployment. In TC Summary Opinion 2018-52,…

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IRS: Certain Exceptions on Transfer Agreements

IRS Offers Guidance on Certain Exceptions on Transfer Agreements The IRS has updated Questions and Answers (Q&As) regarding the Code Sec. 965 transition tax on its website. The new Q&As provide guidance on “transfer agreements,” which are filed in connection with transfers that are intended to avoid accelerating installment payments or triggering deferred tax liability…

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