International Tax News

Tax Court Thwarts Use of Rule 155

Tax Court Thwarts Use of Rule 155 to Raise New Issues In Vento et al., a case decided in February, the U.S. Tax Court has held that the taxpayers involved couldn’t use Tax Court Rule 155 to raise new issues in litigation where they were denied foreign tax credits under Internal Revenue Code Section 901…

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I-9 Audits On the Rise

I-9 Audits Are On the Rise: Be Prepared I-9 audits quadrupled in 2018 over the prior year (the federal fiscal year). That means nearly 6,000 employers were audited, which led to several dozen civil and criminal convictions. The agency involved — Homeland Security Investigations (HSI) — “is carrying out its commitment to increase the number…

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Finalized Section 965 Transition Regs: Adjustments to E&P and Basis

Finalized Section 965 Transition Regs: Adjustments to E&P and Basis 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. Sec. 965 generally requires U.S. shareholders to pay a “transition tax” on the untaxed foreign earnings of certain specified…

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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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