International Tax News

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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Proposed Regs Look To Close CFC Loopholes

The IRS recently issued proposed regs that would amend the controlled foreign corporation (CFC) related party and CFC active rent rules to close certain loopholes. Here are some details on each of the loopholes. Related Party Loophole The IRS is concerned that, in certain situations, the current rules and regs could produce inappropriate results when…

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Court Upholds Freedom of Information Act Exemption for IRS

Court Upholds Freedom of Information Act Exemption for IRS The U.S. Court of Appeals for the Federal Circuit recently handed down its decision in Agrama v. U.S. The case focused on whether the IRS satisfied its Freedom of Information Act (FOIA) burden of showing that it had conducted an adequate search for the documents that…

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Proposed Regs Would Tax S Corporation Income Otherwise Allocable to Nonresident Alien Owners of ESBTs

Proposed Regs Would Tax S Corporation Income Otherwise Allocable to Nonresident Alien Owners of ESBTs The IRS has issued proposed regs that would ensure that the income of an S corporation will continue to be subject to U.S. income tax even when a nonresident alien (NRA) is a deemed owner of a grantor trust that…

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IRS Issues Final Regs on Recognition and Deferral of Foreign Currency Gain or Loss

IRS Issues Final Regs on Recognition and Deferral of Foreign Currency Gain or Loss In May, the IRS issued final regs on the combinations and separations of qualified business units (QBUs) subject to Internal Revenue Code Section 987. The regs also address the recognition and deferral of foreign currency gain or loss with respect to…

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