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Internal Revenue Service › Extraterritoriality Rules

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.  
Foodman CPAs & Advisors

FATCA is still Standing!

Foodman CPAs & Advisors on

Tax Reform came and went and FATCA is still standing. While U.S. Corporations are now moving to a Territorial tax system, Individual U.S. Taxpayers living abroad ARE STILL REQUIRED to REPORT their worldwide income. ...more

Dechert LLP

U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach

Dechert LLP on

The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more

A&O Shearman

Focus on Tax Controversy and Litigation - The Unprecedented Extraterritorialization of Tax Crimes

A&O Shearman on

In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s...more

Carlton Fields

D.C. Circuit Holds That Wholly Foreign Retrocessions Not Subject To U.S. Excise Tax

Carlton Fields on

In late May, the United States Court of Appeals for the District of Columbia Circuit affirmed a grant of summary judgment to a reinsurer in a dispute with the IRS regarding the imposition of U.S. excise taxes on a wholly...more

Eversheds Sutherland (US) LLP

Validus Affirmed for All the Right Reasons – The FET Does Not Apply to Wholly Foreign Reinsurance Transactions

Eversheds Sutherland (US) LLP on

On May 26, the U.S. Court of Appeals for the District of Columbia affirmed the result of the U.S. District Court for the District of Columbia in Validus Reinsurance, Ltd. v. U.S., 19 F. Supp. 3d 225 (2014), which was the...more

Locke Lord LLP

Locke Lord QuickStudy: Validus Court of Appeals Decision - Wholly-Foreign Retrocessions Not Subject to Federal Excise Tax

Locke Lord LLP on

On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more

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