The IRS recently changed the process under which it accepts requests for verification that it has received a filed FinCEN Form 114, “Report of Foreign Bank and Financial Accounts” (FBAR). Before November 19, 2019, the agency allowed FBAR filers to call its FBAR hotline to obtain verbal verification of...
The IRS recently granted relief to certain U.S. persons who own stock in certain foreign corporations affected by the repeal of Internal Revenue Code Section 958(b)(4) under the Tax Cuts and Jobs Act. Revenue Procedure 2019-40 limits the inquiries that U.S. persons must make to determine whether certain foreign...
The start of a new year also marks the start of a new tax season. Even when there aren’t any major tax overhauls at the federal or state level, there are inevitably some adjustments made that, while seemingly small, are important to note. This is once again the case...
Various dollar figures related to international tax are adjusted annually for cost-of-living increases. These adjustments reflect a measure of inflation that was revised by the Tax Cuts and Jobs Act (TCJA) called the average “chained Consumer Price Index (CPI) for all-urban customers.” The adjustments are for the 12-month period...
Are you required to file a 1099 tax form? As a general rule, you should issue a Form 1099-MISC to each person or unincorporated business to whom you have paid at least $600 in rents, services (including parts and/or materials), prizes, awards, medical and health care payments, royalties (at...
In a recent revenue procedure, the IRS updated two lists of countries with which the United States has agreements that require payers to report certain deposit interest paid to nonresident alien individuals who are residents of the other country. One list is of countries with which the United States...
The IRS has revised its general frequently asked questions (FAQs) on the Foreign Account Tax Compliance Act (FATCA). The revisions focus on certification and periodic review requirements involving Qualified Intermediaries (QIs), Withholding Foreign Partnerships (WPs) and Withholding Foreign Trusts (WTs). Here are the pertinent changes: FAQ 2: How should...
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 deemed to be in accordance with the partners’ interests in the partnership. The final regs issued in July adopt...
Cryptocurrencies were the rage until December 2017 when the Bitcoin pricing reached all-time highs of close to $20,000 after having been as low as $1,000 in January of that year. The pricing of Bitcoin was only 7 cents when trading started in 2010. By the end of 2018, the...
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 U.S. shareholders to pay a “transition tax” on the untaxed foreign earnings of certain specified foreign corporations as if...