Taxpayers living and working outside the United States must file their 2021 federal income tax return by Wednesday, June 15. This...

Taxpayers filed their U.S. federal income tax returns as a married couple filing jointly for the 5 years relevant to this letter ruling....

Taxpayers argue that deferred compensation expense earned prior to the enactment of 250(b) Foreign Derived Intangible Income should not...

This is a recent addition to my ‘International Tax Update’ manual: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Base...

On February 15, 2022, the IRS announced an update to the Form 14457, 'Voluntary Disclosure Practice Preclearance Request'. Noncompliance...

On December 14, 2021, the IRS Large Business and International (LB&I) issued a new Practice Unit on flow-through entities and their...

IRS issues proposed regulations on withholding for foreign investors in qualified opportunity zone funds (NPRM REG-121095-19; Apr. 14,...

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,...

Revocation or Denial of Passport in Case of Certain Unpaid Taxes under §7345 §7345 was enacted as part of the 2015 Fixing America’s...

Revocation or Denial of Passport in Case of Certain Unpaid Taxes under §7345 §7345 was enacted as part of the 2015 Fixing America’s...

Form 8832, ‘Entity Classification Election’ Eligible foreign and domestic entities use the Form 8832 to elect how it will be classified...

The TCJA repealed §958(b)(4) which stated that the ‘downward attribution’ rule of 318(a)(3) was not to be applied so as to consider a US...

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...

Noncompliance with foreign reporting obligations such as the FBAR and the Form 8938 ‘Statement of Foreign Financial Assets’ can result in...

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...

Employers sometimes pay housing costs to an employee to cover increased costs of living in a foreign country. The foreign housing...

State Conformity with FDII and GILTI What is deductible or an inclusion for Federal tax purposes may not always be the same for state...

President Biden’s Proposed International Tax Changes The President has signaled his intentions to make changes to the international tax...

What are Foreign Branches Generally, a foreign branch is a division which operates a trade or business in a foreign country and maintains...

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...