Jun 3, 20221 minForms 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...
May 24, 20222 minLate 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, 20221 minDeductions 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, 20224 minManual Update: OECD BEPS and New IRS Practice Unit on CbC ReportingThis is a recent addition to my ‘International Tax Update’ manual: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Base...