Forms 1040 due June 15 for Americans Living Abroad
Taxpayers living and working outside the United States must file their 2021 federal income tax return by Wednesday, June 15. This...
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- May 24, 2022
- 2 min
Late QEF Election Granted to Married Couple Unaware of PFIC Status (PLR 202220014, February 2, 2022)
Taxpayers filed their U.S. federal income tax returns as a married couple filing jointly for the 5 years relevant to this letter ruling....
- May 11, 2022
- 1 min
Deductions are Allocated and Apportioned in Classes Existing in Year Taken (AM 2022-001, 5/6/2022)
Taxpayers argue that deferred compensation expense earned prior to the enactment of 250(b) Foreign Derived Intangible Income should not...
- Apr 27, 2022
- 4 min
Manual Update: OECD BEPS and New IRS Practice Unit on CbC Reporting
This is a recent addition to my ‘International Tax Update’ manual: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Base...
- Feb 24, 2022
- 1 min
2022 Update to the Form 14457, Voluntary Disclosure Practice Preclearance Request
On February 15, 2022, the IRS announced an update to the Form 14457, 'Voluntary Disclosure Practice Preclearance Request'. Noncompliance...
- Jan 27, 2022
- 1 min
New IRS Practice Unit on Foreign Tax Credits and Flow-Thru Entities
On December 14, 2021, the IRS Large Business and International (LB&I) issued a new Practice Unit on flow-through entities and their...
- May 6, 2021
- 1 min
IRS Issues Proposed Regulations on Withholding for Foreign Investors in Qualified Opportunity Funds
IRS issues proposed regulations on withholding for foreign investors in qualified opportunity zone funds (NPRM REG-121095-19; Apr. 14,...
- May 4, 2021
- 1 min
Additional Drafts of 2021 Schedules K2 and K3 Released
Draft 2021 Schedules K2 and K3 Released (IR-2021-98; April 30, 2021) The IRS has released draft Schedules K-2 and K-3 for the Forms 1065,...
- Apr 1, 2021
- 2 min
Certification of ‘Seriously Delinquent Tax Debt’ Does Not Violate Due Process Nor Human Rights
Revocation or Denial of Passport in Case of Certain Unpaid Taxes under §7345 §7345 was enacted as part of the 2015 Fixing America’s...
- Mar 30, 2021
- 1 min
IRS Resumes Certification of Tax Debt to State Department (March 14,2021)
Revocation or Denial of Passport in Case of Certain Unpaid Taxes under §7345 §7345 was enacted as part of the 2015 Fixing America’s...
- Mar 23, 2021
- 3 min
Late Relief Granted for Late Filing of Entity Selection Form 8832 (Ruling 202111010)
Form 8832, ‘Entity Classification Election’ Eligible foreign and domestic entities use the Form 8832 to elect how it will be classified...
- Mar 23, 2021
- 1 min
The Impact of TCJA’s Repeal of the §958(b)(4) ‘Downward Attribution Rule’
The TCJA repealed §958(b)(4) which stated that the ‘downward attribution’ rule of 318(a)(3) was not to be applied so as to consider a US...
- Mar 11, 2021
- 3 min
New Categories of Filers on the 2020 Form 5471
US persons who fall within one of five categories of filers must file a Form 5471, 'Information Return of U.S. Persons With Respect to...
- Mar 9, 2021
- 4 min
Options for Noncompliance with US Foreign Reporting Obligations
Noncompliance with foreign reporting obligations such as the FBAR and the Form 8938 ‘Statement of Foreign Financial Assets’ can result in...
- Mar 4, 2021
- 2 min
The Filing Status Options for a US Resident with a Non-Resident Alien Spouse
The Filing Status Options for a US Resident with a Non-Resident Alien Spouse The US has no jurisdiction over a non-resident spouse who...
- Mar 2, 2021
- 2 min
IRS Releases Housing Cost Amounts Eligible for Exclusion or Deduction for 2021 (Notice 2021-18)
Employers sometimes pay housing costs to an employee to cover increased costs of living in a foreign country. The foreign housing...
- Feb 25, 2021
- 1 min
Illinois Releases Proposed 2022 Budget which Decouples FDII and the GILTI Deduction
State Conformity with FDII and GILTI What is deductible or an inclusion for Federal tax purposes may not always be the same for state...
- Feb 23, 2021
- 3 min
President Biden's Proposed International Tax Changes
President Biden’s Proposed International Tax Changes The President has signaled his intentions to make changes to the international tax...
- Feb 16, 2021
- 2 min
Covid-19 Guidance Regarding Foreign Branches
What are Foreign Branches Generally, a foreign branch is a division which operates a trade or business in a foreign country and maintains...
- Feb 16, 2021
- 2 min
Final Regulations Issued on Sourcing Rules for Sales of Inventory Property (T.D. 9921)
The Sourcing Rules §861-865 The sourcing rules have an important purpose for US persons and non-US persons. Since a US person is taxed in...
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