News & Analysis as of

Foreign Tax

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Ius Laboris

Tax Regulations for ‘Inpatriate’ Employees

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Many countries have special tax regimes designed to attract qualified staff from abroad, and this is part of a series of articles in which we are covering some of these regimes....more

Holland & Knight LLP

IRS Authority to Assess Certain Foreign Information Return Penalties Restored by D.C. Circuit

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The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more

Strafford

[Webinar] Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Income and Expenses, FTCs - March...

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This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more

Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

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It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Foodman CPAs & Advisors

¡Viene El Intercambio De Información De Activos Digitales Offshore!

Las explicaciones generales de la Administración de Biden sobre las Propuestas de Ingresos de la Administración para el año fiscal 2024 analizan la propuesta de informes de intercambio de información por parte de...more

Foodman CPAs & Advisors

Offshore Digital Assets Information Exchange Coming!

The Biden Administration General Explanations of the Administration’s Revenue Proposals for Fiscal Year 2024 discusses the proposal for exchange of information reporting by financial institutions and offshore digital asset...more

Ballard Spahr LLP

IRS Introduces a Domestic Filing Exception to Schedules K-2 and K-3

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Background - The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more

McDermott Will & Emery

Weekly IRS Roundup November 21 – November 25, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 21, 2022 – November 25, 2022...more

Foodman CPAs & Advisors

The FATCA Loophole Will Bring More Enforcement Action

After a yearlong investigation, the US Senate Finance Committee probed into a FATCA Loophole and delivered an investigative report titled “The Shell Bank Loophole” that exposes a tax evasion scheme under a FATCA loophole...more

McDermott Will & Emery

Weekly IRS Roundup August 8 – 12, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 8, 2022...more

King & Spalding

The Norwegian Transparency Act Comes Into Force: Mandatory Human Rights Due Diligence for Large Companies Doing Business in Norway...

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On 1 July 2022, the Norwegian Transparency Act entered into force. It requires that large domestic (Norwegian) companies and foreign companies doing business in Norway implement and account for human rights due diligence in...more

Foodman CPAs & Advisors

“Reciprocal FATCA” Bill Will Be A Game Changer

Under the concept of “Reciprocal FATCA” financial institutions and brokers ought to start preparing to assume greater and expanded reporting responsibilities. As FATCA Stakeholders, financial institutions, and brokers, such...more

Freeman Law

The Section 962 Election

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For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue. Section 962 allows an individual shareholder of a...more

Holland & Knight LLP

The Most Interesting International Tax Proposals in Biden's FY 2023 Budget

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This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage...more

McDermott Will & Emery

Weekly IRS Roundup November 1 – November 5, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 1, 2021 – November 5, 2021. Additionally, for continuing updates on the tax impact of...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

Conyers

The Revenue Rule in the Cayman Islands and British Virgin Islands

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It is well established, under common law principles applicable in the Cayman Islands and the British Virgin Islands that claims for payment of foreign tax liabilities, or claims for the enforcement of foreign judgments for...more

Faegre Drinker Biddle & Reath LLP

Luxembourg Extends Cross-Border Tax and Social Security Agreements with Neighboring Countries

Over the past fifteen months, many countries have introduced creative new approaches to address the economic realities of the COVID-19 pandemic. As employees continue to work remotely and employers reconsider whether...more

Skadden, Arps, Slate, Meagher & Flom LLP

Is Tax Competition Dead?

The G7’s support for OECD-backed tax reforms could mark a big step toward a more consistent, revamped global tax scheme — depending on the details and whether it is actually adopted. ...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and International Tax Changes

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A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

Alston & Bird

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

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Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes....more

McDermott Will & Emery

Proposed Regulations Provide New Rules for Allocating and Apportioning Foreign Income Taxes Relating to Disregarded Payments

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On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a...more

McDermott Will & Emery

Weekly IRS Roundup August 10 – August 14, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

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