Compliance

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...

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...

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,...

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,...

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...

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The TCJA repealed §958(b)(4) which stated that the ‘downward attribution’ rule of 318(a)(3) was not to be applied so as to consider a US...