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Internal Revenue Service Foreign Corporations

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

Swapping Foreign Real Properties On a Tax Deferred Basis

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Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more

Fenwick & West LLP

Domestication with a Twist: A Tax Case Study

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The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

McDermott Will & Emery

Supreme Court Rules Against Taxpayers in IRC Section 965 Case

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On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS)....more

Freeman Law

El IRS actualiza reglas sobre los ajustes a la base gravable en las distribuciones a mitad de año por las CFC para evitar las...

Freeman Law on

Durante años, había existido incertidumbre entre los profesionistas que se dedican a la materia fiscal sobre sobre si las ganancias obtenidas a mitad de año por una Corporación Extranjera Controlada (por sus siglas en inglés,...more

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

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This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

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On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

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On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

Vinson & Elkins LLP

IRS Releases Final Regulations Impacting FIRPTA Exemption for Domestically Controlled REITs

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On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more

Holland & Knight LLP

Treasury, IRS Issue Inbound Corporation Stock Repurchase Excise Tax Proposed Regulations

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Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Issue Proposed Regulations Regarding the Stock Buyback Excise Tax

On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more

Foodman CPAs & Advisors

¿Está Su Preparador De Impuestos De 2023 Haciendo Las Preguntas Correctas?

La temporada de impuestos está aquí y en el 1/2/24, el IRS le recordó a los contribuyentes que elijan cuidadosamente a su preparador de impuestos de 2023 al preparar sus impuestos de 2023. Los contribuyentes son, en última...more

Foodman CPAs & Advisors

Is Your 2023 Tax Preparer Asking You The Right Questions?

Tax season is here and on 2/1/24, the IRS reminded Taxpayers to choose a 2023 Tax Preparer carefully when preparing their 2023 Taxes. Taxpayers are ultimately legally responsible for all the information on their income tax...more

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

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On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

A&O Shearman

Notice 2024-10 Provides Interim Guidance on the Application of the CAMT with Respect to Controlled Foreign Corporations and...

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On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more

Warner Norcross + Judd

The IRS is Shifting Audit Attention to Large Partnerships and Wealthy Individuals

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In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more

Foodman CPAs & Advisors

Understanding Trusts So You Are Not Mislead By The Word “Trust”

Trusts are vehicles that can assist in the preservation of wealth and property for future generations, protect assets, or carry out a charitable purpose. A trust is an entity created and governed under the state law in which...more

McDermott Will & Emery

IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

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On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more

Foodman CPAs & Advisors

Alivio Del IRS Para Ciertos Documentos Internacionales Presentados Tarde

Foodman CPAs & Advisors on

El 11/08/23, el IRS anunció que, en las circunstancias adecuadas, los contribuyentes internacionales podrán utilizar una nueva herramienta totalmente electrónica para presentar solicitudes de alivio de multas del IRS para...more

Foodman CPAs & Advisors

IRS Relief For Certain Late-Filed International Documents

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On 8/11/23, the IRS announced that under the right circumstances, international taxpayers will be able to use a new, fully electronic tool to submit penalty IRS relief requests for a few late-filed forms: a fax...more

Best Best & Krieger LLP

The U.S. Corporate Transparency Act is Almost Here

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This is the second in a two-part series discussing the Corporate Transparency Act (CTA) – new legislation enacted by Congress in January 2021, as part of the Anti-Money Laundering Act of 2020. Read the first part of this...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

Troutman Pepper

FIRPTA and Publicly Traded Corporations

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On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at...more

McDermott Will & Emery

IRS Releases Proposed Regulations Addressing Repatriations of Intangible Property

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BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more

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