The IRS recently issued questions and answers (Q&As) regarding the transition tax imposed by Internal Revenue Code Section 965. Under finalized regs issued early in 2019, Sec. 965 generally requires
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In January 2017, the IRS announced a new audit strategy for its Large Business and International (LB&I) Division known as “campaigns.” With the campaigns, LB&I essentially shifts its examinations based
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”
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
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
2018 foreign income/housing exclusions: Residency/presence tests waived for several countries In a recent Revenue Procedure, the IRS waived the residency and presence tests that apply for purposes of the foreign
If you are looking to do business in the U.S., you will have numerous opportunities to succeed, but there are also some pitfalls for which you should keep a lookout.
Court defines “financial interest” and makes other FBAR rulings In U.S. v. Horowitz, a district court ruled on various issues regarding the Report of Foreign Bank and Financial Accounts
You have probably heard mention of a tax treaty, but you might not be sure what one is or what it entails. Many countries have entered tax treaties with
No matter where you live abroad, you need to pay your income tax if you are a citizen of America. Thus, if you move to the Netherlands, you need to