International Tax News

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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U.S. Residency Certification Request Fee Rises

User Fee Rises for Some U.S. Residency Certification Requests The user fee for processing residency certification made on Form 8802 (“Application for United States Residency Certification“) is increasing from $85 to $185 for non-individual taxpayers. This is effective for forms postmarked on or after December 1, 2018. The announcement was made in IRS Revenue Procedure…

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Major Changes to Revenue Recognition

The Way Technology Companies Recognize Revenue is About to Change Significantly by Andrew Walker, CPA For many technology entities, top line revenue is one of the most important metrics for both business owners and investors. Murky guidance and lack of comparability with international reporting has long been a complaint from the readers of financial statements….

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Proper PFIC Reporting

IRS Advises Taxpayer on Verifying Proper PFIC Reporting In an Information Letter, the IRS has advised a taxpayer, who sold his interest in a passive foreign investment company (PFIC), on the steps to take to verify that he’d properly reported his PFIC transaction and, presumably, determine whether he’s due a refund. PFIC rules were enacted…

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Deadline for 2018 QI/WP/WT Agreements

IRS Reminds Certain Entities of Deadline for 2018 QI/WP/WT Agreements The IRS issued a reminder that the deadline for 2018 status applications for all Qualified Intermediary (QI) entities (including Qualified Derivatives Dealer), Withholding Foreign Partnerships (WPs) and Withholding Foreign Trusts (WTs) is November 16, 2018. This will allow sufficient time for processing by year end….

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