International Tax News

IRS Will Allow Foreign Tax Credit for Previously Noncreditable French Taxes

IRS Will Allow Foreign Tax Credit for Previously Noncreditable French Taxes The IRS has issued a statement saying it will no longer challenge claims for foreign tax credits (FTCs) related to the French Contribution Sociale Généralisée (CSG) and Contribution au Remboursement de la Dette Sociale (CRDS) taxes. Let’s take a closer look. Statutory Rules Internal…

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FATCA: Explanations of Key Certifications and Periodic Review Requirements

FATCA: Explanations of Key Certifications and Periodic Review Requirements The IRS has revised its general frequently asked questions (FAQs) on the Foreign Account Tax Compliance Act (FATCA). The revisions focus on certification and periodic review requirements involving Qualified Intermediaries (QIs), Withholding Foreign Partnerships (WPs) and Withholding Foreign Trusts (WTs). Here are the pertinent changes: FAQ…

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IRS Finalizes Certain Foreign Tax Credit Regulations

IRS Finalizes Certain Foreign Tax Credit Regulations In June, the IRS finalized certain proposed regs pertaining to the foreign tax credit (FTC). The final regs include changes to the rules that address the interaction between the FTC and Internal Revenue Code (IRC) Section 965(n) rules on not applying the net operating loss deduction when calculating…

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Section 956 Update: Final Regs

Final Regs Exclude Corporate U.S. Shareholders From Application of Section 956 The IRS recently issued final regulations that reduce the amount determined under Internal Revenue Code Section 956 for certain domestic corporations that own (or are treated as owning) stock in foreign corporations. Under the regs, neither an actual dividend to a corporate U.S. shareholder,…

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District Court Refuses To Dismiss FBAR Penalty Action Against Decedent’s Family

District Court Refuses To Dismiss FBAR Penalty Action Against Decedent’s Family If you have an interest in (or authority over) a foreign financial account, you may have to electronically file a form called the “Report of Foreign Bank and Financial Accounts” (FBAR). Failing to file a required FBAR can result in penalties. In the recent…

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