The IRS recently issued final regulations on the operation of a safe harbor rule that’s used in determining whether allocations of partnership creditable foreign tax expenditures (CFTEs) to partners are
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
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”
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