International Tax News

Finalized Section 965 Transition Regs: An Overview

Finalized Section 965 Transition Regs: An Overview 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 (TCJA). Sec. 965 generally requires U.S. shareholders to pay a “transition tax” on the untaxed foreign earnings of certain specified foreign corporations…

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Claims Court Upholds FBAR Penalty Exceeding Regulatory Cap

Claims Court Upholds FBAR Penalty Exceeding Regulatory Cap In a recent case, the U.S. Court of Federal Claims granted summary judgment in the IRS’s favor and determined that a taxpayer’s failure to file a Report of Foreign Bank and Financial Accounts (FBAR) was willful. As part of its Kimble v. U.S. decision, the court upheld…

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Iraq-Based Worker Was Entitled to Foreign Earned Income Exclusion

Iraq-Based Worker Was Entitled to Foreign Earned Income Exclusion The U.S. Tax Court has determined in Wentworth v. Commissioner of Internal Revenue that a taxpayer who worked for a security company in Iraq was a “qualified individual” entitled to the foreign earned income exclusion for the years at issue. Here’s a closer look at how…

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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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