The European Court of Justice dismissed Nike’s request to annul the European Commission’s probe into illegal Dutch tax deal.
The European Court of Justice dismissed Nike’s request to annul the European Commission’s probe into illegal Dutch tax deal.
Effective July 1, 2021 the EU’s broad e-commerce package came into effect. The reform aims to modernize VAT for cross-border e-commerce.
The IRS ruled that a plan of reorganization tied a series of steps together even though they were anticipated to span over five years.
The IRS has recently released new draft instructions for schedules K-2 and K-3 for international tax reporting purposes.
A primer on a nonresident’s tax obligations when disposing of Taxable Canadian Property or Taxable Quebec Property.
President Biden proposed changes to revamp the U.S. international tax system significantly affect multinationals in the technology industry
Build your foundation of understanding about the complexities of VAT and GST and the impact they can have on U.S. multinational businesses.
Understand the impact new GST/HST rules may have on distribution platform operators and what you can do before July 1 to be ready.
Digital assets may be impacted by value added tax and digital services tax implemented by various jurisdictions.
Overview of the SEP rules that are important for multinational entities to consider while conducting business in India.
Is a payment to a life science company monetizing a royalty stream a loan or sale proceeds? Is the income ordinary or capital?
The European Commission proposes a new framework for business taxation with measures that promote an effective tax structure in the EU.
G-7 agreement on a 15% global minimum tax could end the race to the bottom in global taxation, but global and U.S. outlooks remain complex.
During conversations on Saturday June 5, 2021, the G7 made historic strides toward multilateral agreement on a 15% global minimum tax rate.
Ninth Circuit reverses Tax Court, based on Congress’ provision of tax benefits based on form rather than substance.
As a sponsor of SelectUSA’s Investment Summit, RSM provides the guidance and insight foreign investors need to invest in the United States.
Join RSM Canada on June 7 to learn more about GST/HST changes for businesses outside of Canada who sell remotely to customers in Canada.
Organizations earning fees for digital products and services from residents of Canada may be required to register for GST/HST.
Hear perspectives from RSM about transfer pricing trends and planning opportunities for the life sciences industry.
RO certifications for the Dec. 31, 2020 period are due July 1, 2021. RSM can assist ROs with this and other FATCA compliance requirements.
The Treasury just released a report proposing how cryptocurrency compliance will contribute to funding the $80 billion IRS overhaul.
The European Court of Justice refused to uphold the European Commission’s ruling that Luxembourg provided illegal state support to Amazon.
Mexico bans subcontracting arrangements. Companies need to act by Aug. 23 2021 to avoid tax, legal and judicial consequences.
IRS issues procedures for certain foreign corporations to implement required or optional ADS depreciation changes.
There are many things to consider when sending employees abroad on short-term assignment. Here’s the top things you should keep in mind.
After 17 months of internal discussions, the German administration approved a draft bill to implement the EU Anti-Tax Avoidance Directives.
Potential improved withholding tax rules for non-U.S. investors with qualified opportunity zone investments and some potential challenges.
U.S. private equity and venture capital funds with German investors have an additional 6 months to file German partnership returns for 2019.
The international tax landscape is shifting based on recent reports from the White House, Senate Finance Committee and U.S. Treasury.
As business models grow more complex, we’re debunking some commonly held misconceptions about how companies think about transfer pricing.
2020 regulations expand the scope of the foreign tax redetermination rules, increasing compliance burdens in many cases.
There are approximately 200 family offices established in Singapore managing $20 billion of assets, and these numbers will likely grow.
Netherlands Budget Day 2021: An overview of important corporate and international tax developments to be aware of in country
Nonresidents of Canada could face significant Canadian sales tax compliance obligations effective July 1, 2021.
In response to the pandemic, the Canadian government introduced support programs that could benefit U.S. multinationals.
French court expands definition of dependent agent for purposes of Permanent Establishment (PE) determination.
Companies doing business in, or through India, should evaluate the impact proposed in the India’s 2021 budget released Feb. 1.
Reduction of participation exemption for dividends and capital gains earned by Spanish entities increases corporate tax rates by 1.25%.
Information on the instant asset write-off and tax loss carryback measures in Australia with potential tax savings for clients.
Devaluation caused by the pandemic may turn your company into a PFIC. However, there may be ways to mitigate tax costs.
Now that we are post-Brexit and new rules have been released, companies must quickly move from planning to execution stage.
Mexico released tax changes for 2021. Some new rules may have significant impact on U.S. companies doing business in Mexico.
Partially finalized regulations on business interest expense deductions provide helpful clarifications for multinational businesses.
Global compensation and outlook for mobile employees and the unprecedented impact on managing global mobility programs.
The OECD’s guidance illustrates how the pandemic may impact arm’s length results, including lower profits and even losses.
Taxpayers should familiarize with Biden’s plan, remain vigilant for developments and position themselves to act at the appropriate times.
UK government provides relief from DAC6, reducing the scope of reporting for UK intermediaries with cross-border transactions.
A look at the impact of Brexit on tax treaties and on the operation of tax law internationally in the new year.
Some European member states are extending the application of the anti-hybrid rules to common non-abusive structures.
German tax may apply to payments for the licensing or sale of German registered IP, even if neither party resides in Germany.
China has dominated global supply chains, but with rising labor costs, a U.S.-China trade war and the COVID-19 outbreak, this may change.
IRS finalizes regulations coordinating the section 245A extraordinary disposition rule with the section 951A disqualified basis rule.
The IRS moved away from a decades old agreement and emerged victorious in the $3.3 billion tax dispute with the beverage company.
Cayman Islands just launched its new DITC portal and extended the due date for filing FATCA and CRS reports to Dec. 16, 2020.
IRS Announcement 2020-12 clarifies that lenders need not issue form 1099-C reporting PPP loans eligible for forgiveness under the CARES Act.
The political and social landscape in the oil and gas industry is changing, and companies without an ESG strategy will fall behind.
Recent changes by Indian tax authorities on taxing dividend distributions may impact U.S. investors’ repatriation of earnings.
Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.
Join our webcast to learn about the unique challenges U.S. businesses face when engaging in online sales of goods and services overseas.
The CARES Act enacted a temporary suspension of the TCJA’s 80% limitation on the use of NOLs, this will impact FTC and ODL calculations.
Final FTC regulations provide clarity while Treasury takes a stance against permitting a credit for digital taxes in new proposed rules.
Updated IRS materials suggest a renewed and heightened focus on the reporting of virtual currency transactions by taxpayers.
Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.
RSM India covers the complex cross-border tax considerations and reporting requirements applicable to nonresident Indians in this guide.
Key actions companies doing business in the United Kingdom should consider as the UK’s transitional period with the EU comes to an end.
On Sept. 1, 2020, the Treasury released final regulations on the section 59A base erosion and anti-abuse tax (BEAT).
The U.S. State Department informed Hong Kong authorities that the shipping agreement between the countries has been suspended or terminated.
IRS releases final and proposed regulations on the deduction for dividends from foreign corporations and related reporting rules.
Organizations that translate lessons learned from COVID-19 into future ready standards can create value that will last beyond this crisis.
Changes in global mobility and immigration and how these affect international assignment programs for global employers.
Taxpayers may not be aware that their business activities with Canada may give rise to a reporting requirement, or even a tax liability.
Former Vice President Joe Biden’s tax plan features significant changes. Rates seem likely to rise, even if President Trump wins re-election
Global mobility requires cross-border tax planning with a global perspective, assignment planning and payroll reporting obligations.
Understanding the global landscape and keeping an eye on regulations, RSM can help businesses unlock efficiencies and realize tax savings.
Recent memo provides IRS view that certain stockless contributions create a split holding period on the stock.
Final regulations generally taxpayer-favorable versus 2018 proposal, additional proposed regulations give guidance on pass-throughs, others.
Final and proposed regulations related to the GILTI high tax exclusion and subpart F high tax exception released.
Treasury and the IRS have issued final regulations on determining the amount of the deduction for FDII and GILTI.
OIRA has begun reviewing the FDII and GILTI deduction regulations and the final regulations are expected to be released soon.
RSM creates a holistic solution to solve the multifaceted complex business issues a company faces when it considers global expansion.
IRS FAQs outline procedures for alien individuals in U.S. to claim the medical condition exception to avoid U.S. resident status.
Careful attention to transfer pricing policies can help middle market companies identify opportunities in the current market turbulence.
Recently published IRS guidance provides insight into the Service’s expectations regarding transfer pricing documentation
Technology subsectors are not immune to the economic shock of COVID-19. However, they could see growth during this perilous environment.
Treasury released guidance indicating that references to NAFTA can be interpreted as USMCA for purposes of U.S. tax treaties.
In response to the COVID-19 crisis, the European Commission has formally proposed the deferral of certain deadlines under DAC6.
Finalized section 385 debt-equity regulations proposed in 2016, government still plans to issue some less harsh rules in the future.
Here are some ways coronavirus could leave its mark on the global VAT, trade and tariff landscape for the life sciences industry.
Time in U.S. counts as time in a foreign country under foreign earned income exclusion for taxpayers who returned to U.S. due to COVID-19.
The U.S., Cayman, and other jurisdictions extend deadlines for filing FATCA and CRS reports, but exams and compliance programs continue.
The economic impact of COVID-19 is immense. Distressed companies in need of capital may drive future M&A deals.
Nonresident alien individuals unable to leave the U.S. because of travel restrictions may avoid U.S. resident status under new IRS guidance.
France enacted an intellectual property tax regime. Find out what this means for U.S. multinational businesses with operations in France.
In late March 2020 Mexico’s Secretary of Health issued measures that are to be followed in response to the COVID-19 pandemic
Globally mobile employers and their employees may face complications in addressing the individual rebates provided by the CARES Act.
A foreign tax credit transaction that was previously referenced in Notice 2004-20 has been removed by the IRS.
IRS announces new July 15, 2020 deadline for Americans living abroad, nonresident aliens, and foreign corporations.
Act contains broad relief for individuals and businesses; includes funding vehicles, recovery payments, and modifications to TCJA provisions
Today, the House of Representatives passed the CARES Act on a voice vote and the President signed the bill enacting it into law.
CARES Act provides general increase to the limitation amount (i.e., the maximum allowable deduction) and special rule for partnerships
Coronavirus Aid, Relief and Economic Security Act provides liquidity by providing five-year NOL carryback and other help for corporations.
Cayman Islands has extended the deadline for filing 2019 FATCA and CRS reports to September 2020 and intends to launch a new portal.
Global employers need to be aware of the risks they face as they navigate through the complexities posed by COVID-19.
On March 19, the U.S. Senate released the third round of emergency assistance resulting from the 2020 COVID-19 pandemic.
A taxpayer was assessed willful failure to file FBAR penalties after voluntarily withdrawing from OVDP program.
Rev. Proc. 2020-17 grants information reporting and penalty relief to individuals with respect to applicable tax-favored foreign trusts
Altera petitions the Supreme Court of the United States to hear case regarding validity of cost sharing arrangement regulations.
U.S. investment funds, banks and other FIs with foreign investors may need to remediate volumes of tax withholding certificates.
Tax Policy Now podcast examines filing tax returns now or pursue an extension, given the wait for Treasury Department legislative action.
Advisor must document amounts used to “investigate” an actual buy or sell – a study may make sense if amounts are substantial.
In early September, Mexico released a proposed tax reform package with significant changes in the country’s international tax regime.
IRS has issued final regulations narrowing nonrecognition treatment for certain transfers of property to partnerships with foreign partners.
The IRS is willing to consider relief from double taxation resulting from the application of section 965 in limited circumstances.
RSM’s tax leaders bring insight on upcoming policy shifts for the Tax Cuts and Jobs Act in a short audio cast.
There are five key actions to take now to prepare to file information returns in January to ensure compliance with FATCA.
RSM's virtual summit on transformative tax issues facing the middle market is available as an on-demand webcast.
Join us for a webcast to learn about IRS trends and changes in U.S. tax information reporting and withholding requirements.
The IRS finalized rules for withholding and reporting U.S. source payments to foreign individuals and financial institutions.
DAC 6 will introduce five different “hallmark” categories that represent an indication that a transaction may have a risk of tax avoidance.
DAC 6 reporting by intermediaries implementing or advising on certain cross-border arrangements in EU member states starts July 2020.
Newly released foreign tax credit regulations address tax reform changes, clarify existing rules and provide new elections and safe harbors.
Final regulations affect whether a controlled foreign corporation is a related person under attribution rules.
The IRS has published final section 6050Y regulations requiring reporting of sales and acquisitions of certain life insurance contracts.
New IRS enforcement campaign targeting the section 965 transition tax compliance indicates a likely increase in section 965 audit activity.
Business tax year-end webcast: Update on federal, international and pass-through tax considerations for year-end planning
The U.S. Senate approved treaty protocols that will affect the taxation of pension plans between certain contracting states.
Although not effective until July 2020, DAC 6 reporting obligations retroactively apply to transactions occurring on, or after June 25, 2018
New guidance from the UK’s Her Majesty’s Revenue and Customs provides more clarity for businesses engaged digital asset businesses.
IRS to retain regulations treating some related party debt as equity, but will propose rules easing one of the regulations’ harshest rules.
Data is the new battleground for tax authorities. Businesses should take steps to assure the quality and integrity of their data.
All companies seeking QI, WP, or WT status for 2019 must apply by Nov. 15, 2019 to have an agreement in effect.
The IRS has published a long-awaited practice unit as guidance for examinations of electronic books and records under section 1441.
As of Jan. 1, 2019, foreign non-resident taxpayers conducting business in Quebec are required to register for the Quebec Sales Tax.
A business guide to tax considerations for 2019 to help make informed decisions after the Tax Cuts and Jobs Act.
U.S businesses with operations in the Netherlands may be impacted by the 2020 Tax Plan proposed on Sept. 17, 2019.
New IRS cryptocurrency guidance provides much needed clarity but may require changes to returns not yet filed.
More than $750bn VAT revenue has been lost across the EU over a 5-year period from VAT fraud and more significantly to noncompliance.
Proposed rules limit the impact and reduce the reporting burden caused by tax reform changes to CFC ownership rules.
India’s sweeping corporate tax cuts, effective retroactively to April 1, 2019, makes the country a viable investment destination in Asia.
The IRS announced new relief procedures from paying back taxes for certain former citizens who wish to become compliant.
This webcast will focus on examining the effect of tax reform on pass-throughs at international, state and local levels.
A robust look at several significant international provisions for foreign-derived intangible income, also referred to as section 250.
Fluctuation in value of stock did not impact exception to gain recognition, but no ruling on overall tax-free nature of reorganization.
IRS answers a few important questions regarding the taxation and withholding rules for uncashed distribution checks.
The introduction of the services cost method concept to the Base Erosion Anti-Abuse Tax (BEAT) is a welcome benefit to some taxpayers.
Proposed regulations provide guidance on classifying cloud transactions and income sourcing for transfers of digital content.
Cost-sharing arrangements remain in flux as Altera continues. Taxpayers should monitor the developments to ensure appropriate alignment.
Effective Nov. 1, 2019 Polish tax authorities announced they will introduce what is known as a Split Payments Mechanism (SPM).
Final regulations issued in late June 2019 on GILTI inclusion could have a considerably differently impact on PE and VC fund structures.
Answers to questions about the most common tax related issues for U.S. citizens and residents starting an assignment abroad.
If a fund is organized as a partnership, and has German investors, the annual filing of a partnership return in Germany is required.
A refund opportunity exists for taxpayers who paid the CSG and CRDS French social taxes thanks to new guidance from the IRS.
Revisions to the U.S. income tax treaties with Switzerland, Luxembourg, Japan and Spain may pass the Senate after years of being stalled.
Final regulations reduce the amount determined under section 956 for certain domestic corporations that own stock in foreign corporations.
Final and new proposed GILTI and Subpart F regulations provide significant relief to private equity and other non-corporate taxpayers.
Treasury and the IRS finalize and withdraw certain provisions contained in previously issued temporary section 987 regulations.
The IRS issued proposed regulations designed to clarify and modify the rules for foreign pensions investing in U.S. real property.
The IRS has issued guidance for withholding agents on the submission of delinquent international withholding forms.
U.S. businesses providing certain services and digital goods to individuals in Quebec may have Quebec sales tax compliance obligations.
The new disclosure will likely be used to gauge virtual currency noncompliance and may require disclosure of the six most recent tax years.
Withholding generally applies to transfers of partnership interests by foreign persons, regulations generally follow previous guidance.
Cayman Islands will accept Cayman FATCA and CRS reports, originally due May 31, through July 31, 2019, without penalty.
Not all digital assets are received through an exchange; airdrops and hard forks create another layer of complexity for taxpayers
Changes to the international tax system will require U.S. taxpayers to navigate important foreign tax credit transition rules.
Intersection of GILTI rules and business interest expense limitation rules creates opportunity to characterize interest expense.
Understanding the impact GILTI will have on your multinational organization may maximize tax planning opportunities and minimize risk.
With the second installment of taxpayer’s section 965 liability due soon, there are several items to remember before the filing deadline.
Carefully consider international blockchain enterprise structuring in light of the Tax Cuts and Jobs Act (TCJA)
The deadline for QI/WP/WTs to submit applications to form a consolidated compliance group for certifications due in 2019 is April 1, 2019.
Listen to business and professional services tax professionals provide analysis of tax issues affecting the industry.
The IRS issues new FAQs providing relief from withholding tax penalties on certain dividend equivalent payments and undistributed earnings.
This alert details upcoming deadlines for Forms 1042/1042-S, FATCA Reports, RO Certifications and FBAR filings.
Double tax on dividends received by United States shareholders from foreign corporations addressed via TJCA through section 962.
Proposed regulations for section 250 deductions provide multi-step process to account for NOL deductions and interest deduction limitation.
Treasury and IRS issue proposed guidance on global intangible low-taxed income and foreign-derived intangible income deductions.
Court imposes substantial “willful” penalty for failure to file FBAR where taxpayer fails to consult tax advisor regarding foreign account.
Legislation relating to the Base Erosion and Profit Shifting (BEPS) Action Items has resulted in expanded tax due diligence engagements.
Brexit uncertainty requires complex scenario planning. How can business leaders prepare now to minimize risk along an unclear path?
The E&P of upper tier CFC partners of a domestic partnership must be increased as a result of the partnership’s subpart F income.
For companies moving goods between the E.U. and the U.K., there are practical steps to take now to improve your readiness for a hard Brexit.
Recently issued proposed regulations provide election that may allow multinational businesses to increase their interest deduction.
US companies with VAT obligations in the United Kingdom should understand and prepare to comply with Making Tax Digital.
Final section 965 regulations extend the deadline to make, or amend a previously made, basis adjustment election to May 6, 2019.
Taxpayers can avoid accelerating section 965 deferred transition tax payments if they file agreement by March 7, 2019.
Efficiently and effectively manage your global value added tax compliance with a strong risk management process.
The Internal Revenue Service has released final Section 965 forms, schedules and instructions for taxpayers to use this filing season.
U.S. companies with operations in Mexico should carefully analyze the applicability of the Income Tax and VAT Credits.
Final regulations addressing the implementation of the section 965 transition tax have been released by the IRS.
Companies in the U.K. face withholding tax on intercompany interest, royalties and dividends from related parties in the EU.
Newly introduced tax reform technical corrections bill will serve as the roadmap for future legislative tax correction packages.
The Mexican government has introduced two tax stimulus credits for certain taxpayers operating in the northern states.
U.S. companies with Mexican subsidiaries should re-examine whether they are at risk of audit, or of losing the use of their NOLs.
Regulations would implement law requiring gains on the sale of some partnership interests to be treated as connected with a US business.
New proposed regulations implement sections 245A(e) and 267A regarding hybrid dividends and transactions with hybrid entities.
Treasury and IRS plan to issue regulations addressing issues affecting foreign corporations with previously taxed earnings and profits.
The IRS and Treasury have recently released proposed regulations regarding the new Base Erosion and Anti-Abuse Tax (BEAT).
The IRS has issued new FAQs for the 2018 tax year to provide guidance on filing and payment obligations under section 965.
Proposed regulations reducing burdens under the Foreign Accounts Tax Compliance Act and Chapter 3 provide relief for Withholding agents.
The deadline for FFIs to certify compliance and confirm their status rapidly approaches. Login to the FATCA portal now to avoid exposure.
If you provide services through the internet, chances are you have value-added tax collection and filing obligations.
Understand the complexities associated with global reporting and withholding requirements for US private equity funds with foreign investors
The IRS is gearing up for its 1042 and 1042-S compliance campaign slated to begin in early 2019 with focus on common errors.
IRPAC’s recent report proposes changes to withholding and reporting requirements for loan fees, deemed dividends, and 871(m) transactions.
The IRS has issued new FAQs to provide clarification and guidance for the filing of section 965 transfer agreements.
Entities seeking Qualified Intermediary, Withholding Foreign Partnership or Trust agreements must submit applications by Nov. 16.
The IRS has published a new Form W-9 and revised Pub. 1281 reflecting TCJA’s reduction in the backup withholding rate from 28 to 24 percent.
The IRS released proposed regulations that eliminate the current tax on certain off-shore income deemed repatriated.
IRS expands the list of international tax specific issue-based compliance campaigns identified by the LB&I division of the IRS.
IRS has informally announced their intent to delay and eventually eliminate FATCA withholding on certain gross proceeds.
The IRS is reconsidering the traditional rule requiring revenue to satisfy the active trade or business requirement of section 355.
Tax deferral sought by Exelon denied; deficiency and penalty amounts in excess of $526 million affirmed on appeal.
A “Special Update” to the IRS transition tax FAQs grants an extension of the deadline for filing section 965 transfer agreements.
Some e-file software does not conform to IRS guidance for S corp shareholders wishing to make a 965(i) election, and they must paper file.
The IRS announces that it intends to extend the period in which to make a basis election under the transition tax regulations.
Transition period limiting instruments in scope of new section 871(m) have been extended for another two years, until Jan. 1, 2021.
Election to pay tax on Subpart F income at corporate rates doesn’t create imaginary domestic corporation for other purposes.
IRS and Treasury clarify that since GILTI is treated similarly to a subpart F inclusion, GILTI is not includable in calculation of UBTI.
Proposed regulations would require complex calculations and new record keeping to comply with new tax laws on offshore income.
Withholding agents should be prepared to begin collecting new Forms W-9 when the form is finalized which could be as early as Oct. 2018.
Tax Court finds that PFIC gains are not included in current-year gross income and losses from PFIC shares do not offset gains.
Global investors in U.S. real estate need to consider how their investment structure can affect income taxes and reporting requirements.
More than two million ITINs will expire at the end of 2018, be sure you've taken the steps to ensure you don’t have any disruptions.
Second Circuit says 10-year statute of limitations on refunds applies only where taxpayer claims foreign tax credit and not deductions.
IRS memorandum reiterates that the Service may not issue refunds for overpayments where transition tax balance is due.
The Ninth Circuit has withdrawn its July 24 Altera opinion in favor of the IRS while a reconstituted panel considers the opinion.
IRS’ attempt to re-characterize loan as a distribution from subsidiary’s earnings fails under debt-equity principles.
The Court of Federal Claims held that IRS’s authority to impose penalties for willful failure to file FBARs is not limited to $100,000.
Proposed regulations addressing the implementation of the section 965 transition tax have been released by the IRS.
The IRS has completed its upgrade to include the COPA and periodic certification process to the FATCA Registration System.
The IRS has announced that it will upgrade its FFI Registration system; FFIs must confirm their FATCA classifications for RO certifications.
Despite the upcoming termination of the OVDP program, other IRS programs remain for taxpayers to use to cure certain errors.
Entering the U.S. market without adequate planning or implementation can lead to diminished returns on your investment.
A guide for multinational corporations regarding country-by-country reporting questions and base erosion profit shifting.
Taxpayers must consider financial statement impact of the unexpected reversal of the full Tax Court decision in Altera.
IRS released memoranda defining the standard for willful failure to file FBAR penalties. IRS determined it is a civil standard.
From planning to analysis to documentation to implementation, a transfer pricing guide for internationally active middle market companies.
Taking advantage of global opportunity often means expanding into numerous foreign jurisdictions. Learn more here.
Final anti-inversion regulations largely follow the 2016 proposed regulations with some limited changes and clarifications.
The LB&I division of the IRS has identified several international tax issues to be the focus of their new issue specific audit strategy.
The IRS has published a new FATCA FAQ on good faith standard for QIs that comes amidst other information reporting updates.
Learn the valuation impacts resulting from the TCJA and its effect on business owners and investors assessment of ownership interests.
The IRS has announced that it is currently planning to launch the FATCA certification portal in late July or early August.
New FAQs provide relief for certain taxpayers with Q1 2018 estimated tax underpayments or missed installment elections.
Recent informal comments from an IRS official underscore need for partnerships to ensure they have accurate Forms W-8 on file for investors.
New proposed regs amend rules for determining whether a taxpayer is required to e-file 1099, 1042-S, and other information returns.
Cayman Islands effectively extends FATCA and CRS reporting deadline by granting relief from penalties until the end of July.
A district court found that FBAR penalties cannot exceed a regulatory cap of $100,000, despite the relevant statute allowing higher amounts.
The 30 percent rule intended to attract foreign talent to the Netherlands is changing from eight to five years.
IRS alert highlights a scam that uses the complicated requirements of foreign withholding and reporting certificates to prey on taxpayers.
Constructive distributions resulting from bargain sales between related parties triggered withholding tax and penalties.
Tax Court rules transfers between entities resulted in constructive distributions that were subject to withholding tax.
IRS issues significant last minute 2017 income tax payment guidance affecting taxpayers subject to the section 965 repatriation tax.
Taxpayers and practitioners should note several new developments with respect to CRS as they ready for the FATCA/CRS reporting season.
IRS substance-over-form argument to re-characterize transactions between a DISC and IRA as excess contributions rejected by First Circuit.
With all the attention given to cryptocurrencies, it’s time to take a look at what the potential tax implications may be for 2017 taxes.
Treasury and IRS release additional guidance regarding the computation of the section 965 transition tax on the untaxed foreign earnings.
Life sciences companies making payments to related foreign parties should be aware of how to determine the gross receipts calculation.
IRS provides interim rules with respect to withholding tax on the sale of a foreign partner’s partnership interest.
Expats have concerns with new assignments, not the least of which are tax issues. Advance planning can minimize issues down the line.
The IRS has provided more guidance to help taxpayers meet their filing and payment requirements for the section 965 transition tax.
The IRS loosens foreign taxpayer identification number collection requirement amidst new information reporting developments and deadlines.
District court upholds IRS summons issued to U.S. law firm pursuant to an information exchange request from the French tax authority.
The IRS announced it will begin the process of ending the 2014 Offshore Voluntary Disclosure program, with a closure date of Sept. 28, 2018.
Using decreased corporate income tax rates, German-owned companies in the US may be able to significantly reduce their overall tax burden
Join RSM US professionals for this one-hour on-demand webcast as we discuss how tax reform affects foreign-owned companies.
The IRS issued guidance concerning foreign corporations electing to change their taxable year-end in an attempt to defer transition tax.
Petitioner argues to Supreme Court that $1 million FBAR penalty violates U.S. constitution and US-Swiss treaty.
India’s Central Board of Direct Taxes has recently introduced draft rules for public comment that implement master file and country-by-country ...
Treasury official suggests government may not have authority to grant relief for foreign corporations caught by ‘downward attribution’ rule.
IRS issues additional guidance addressing the calculation earnings and profits, and other aspects of the new one-time repatriation tax.
The FASB recently issued Q&As to address certain accounting issues raised by TCJA. Following is our summary of the FASB Staff Q&As.
Tax Court found CFC’s guarantee of parent’s loan to be an investment in U.S. real property, and thus resulted in income inclusion.
Mobility professionals should consider these four important tax reform changes and the cost impact of the new law on their businesses.
Successfully repatriating employees needs thorough planning to ensure ongoing satisfaction for organizations as well as their expatriates.
Taxpayers with international activities will quickly realize that tax reform has taken the complex world of international taxation and added ...
Tax reform has been signed into law. Read RSM’s summary of the major business, international and individual tax provisions.
Proposed regs issued by the IRS provide guidance on treatment of foreign currency gain or loss of a CFC under business needs exclusion.
The IRS has released new Frequently Asked Questions that provide additional guidance with respect to several issues.
Ninth Circuit affirms treatment of investment in a foreign corporation as debt, resulting in denial of foreign tax credit.
As new tax bills are proposed and debated, U.S. companies may want to explore the effect on their expatriate workforce, particularly with respect ...
Global expansion can be the right answer for many companies looking to grow, let RSM help you determine the right global strategy.
The Dutch government has proposed reducing its corporate and withholding taxes along with other significant changes.
Canada-U.S. competent authority agreement for the automatic exchange of country-by-country information has been released by the IRS.
Netherlands expands scope of dividend withholding tax rules for 2018 even while it considers permanent repeal beginning in 2019.
Review legislative changes and other tax concerns that affect 2017 tax compliance and how to plan for 2018. Download our guide.
India releases draft “Master File” filing requirements that would apply if certain revenue and transactional thresholds are met.
10-year foreign tax credit limitation period does not apply to taxpayer who claimed a credit but later amended return to claim a deduction.
The IRS and Treasury will delay the effective date of recently issued complex foreign currency regulations by one year.
District court holds Obama-era anti-inversion rules were implemented without providing taxpayers an appropriate comment period.
New guidance released by the IRS formally eases the mandate requiring banks and other withholding agents to collect FTINs.
District court determines taxpayer’s failure to include one of his two Swiss bank accounts on his FBAR report was not “willful.”
Learn more about the introduction of VAT in middle east and practical next steps you can take to ensure your organization is ready.
Proposal includes welcome aspects, but its potential applicability to ordinary bad debt deduction rules is uncertain and possibly adverse.
Cayman confirms FATCA portal to remain open after deadline, while IRS separately confirmed relief for mandate to collect foreign ID numbers.
Read RSM partner Daniel Berman interview with BEPS Global Currents regarding the OECD BEPS Multilateral Instrument.
Federal Court denies treaty benefits under Swiss treaty because tax avoidance was principal purpose behind creation of Swiss company.
A manufacturing company looking to expand its operations globally was challenged by complex international tax structuring needs-enter RSM.
Germany looks to software for aid in efforts to locate foreign business failing to pay VAT on certain electronic sales prior to 2015.
Ninth Circuit upholds Tax Court’s decision that a couple failed to prove they were entitled to a foreign earned income exclusion.
Postponement of dividend equivalent withholding effective dates granted in late 2016 have been further extended by one year.
As part of Germany’s efforts to implement the OECD’s BEPS Action Plan, expense deductions will be limited for payments after Dec. 31, 2017.
Foreign financial institutions that are otherwise in compliance with the terms of their agreements now have until Oct. 24, 2017 to renew.
IRS arguments on appeal provide useful insight for taxpayers into IRS consideration of transfer pricing cases.
The Tax Court rules that the IRS’ attempt to cancel taxpayer’s APAs without basis was an abuse of discretion.
The Cayman Islands has recently extended, for the final time, the deadline for US FATCA & CRS reporting to Aug. 31, 2017.
A recent opinion by the Advocate General (AG) for the European Court of Justice (ECJ) opens the door for pharmaceutical companies to potentially ...
New IRS guidance on country-by-country (CbC) reporting highlights useful information and additional resources.
Court holds that gain on sale of interest in U.S. partnership is not taxable, rejecting long-standing IRS guidance.
Treasury has recently identified eight regulations that impose undue burden or complexity, or exceed the statutory authority of the IRS.
IRS issues final versions of Form 8975, Country-by-Country Report, Schedule A thereto, and accompanying instructions.
Years ago it was not unheard of for taxpayers to file their international information returns with the entity’s name, maybe a foreign tax ID ...
Revised Form W-8IMY contains new certifications and treatments to better align with requirements in final and temporary regulations.
IRS Chief Counsel issues guidance on foreign deferred compensation plan tied to U.S. deferred compensation plan (a back-to-back plan).
Cayman Islands extends deadline for Cayman financial institutions to provide notification of their intent to file FATCA and CRS reports.
New audit guidance released regarding the meaning of ‘substantially complete’ with respect to international information return penalties.
As the BEPS action plan continues to be developed and implemented, middle market companies need to understand the implications.
The IRS may provide relief to certain financial institutions required to collect foreign TINs by Jan. 1, 2018.
IRS news release notifies taxpayers with foreign contacts of new and pending filing deadlines as well as other reporting requirements.
New audit guidance provides agents with a roadmap to assist in auditing multinational entities’ functional currency determinations.
IRS executes competent authority agreements with three new countries, Iceland, South Africa and New Zealand, bringing U.S. total to five.
Officials from 76 jurisdictions, not including the United States, met to sign the BEPS multilateral treaty instrument.
CCA supports taxpayer’s section 163(j) calculation of adjusted taxable income that does not take into account the proposed regulations.
Australian court sides with government and finds that Chevron’s internal group interest expense was excessive.
The IRS has confirmed that two country-by-country competent authority agreements have been signed, one of which was with the Netherlands.
BEPS Action Item 13 provides new guidance for transfer pricing documentation and country-by-country reporting for US multinationals.
Updated UN transfer pricing manual means taxpayers should be wary of their transfer pricing positions, particularly in developing countries.
When entering the U.S. tax system through investment or relocation, a nonresident faces unique tax reporting and filing obligations.
The U.S. Tax Court ruled against the IRS and concluded that Amazon properly priced the value of certain pre-existing intangibles to be used in ...
New rules for foreign-owned disregarded entities give IRS obligatory information under tax treaties, information exchange agreements.
Final regs update some categories of subpart F income, treatment of foreign-held U.S. property in transactions that involve partnerships.
Learn what financial institutions need to know to comply with the Common Reporting Standard and the Foreign Account Tax Compliance Act.
Tax Court ruling could encourage taxpayers to use comparable uncontrolled transactions method to value buy-in payments.
The Sixth Circuit Court of Appeals overruled the Tax Court and ruled against the IRS to allow a taxpayer to own a DISC through a Roth IRA.
Notice 2017-21 gives taxpayers working abroad a boost to the housing expense limitation under section 911 for certain high-cost locations.
IRS issues compliance reminders to non-U.S. citizens and U.S. withholding agents that they may have U.S. filing obligations.
Many proposed tax law changes will not only affect federal and international tax positions, they will also impact on state and local taxes.
The Sixth Circuit disagreed with the IRS using substance over form to recharacterize DISC dividends as excess Roth IRA contributions.
Learn how RSM helped a nonprofit increase transparency into accounting process across numerous global locations.
Regulations make technical changes to section 871(m) withholding rule but questions about legal effect remain in light of regulation freeze.
The bill is part of Germany’s efforts to implement the OECD’s BEPS Action Plan, passage expected by September 2017.
Regulations provide rules governing contributions of property to a partnership having a foreign partner related to the contributing partner.
IRS provides guidance for early filing of country-by-country report for accounting periods beginning Jan. 1, 2016.
The IRS has published new FFI and QI agreements along with temporary regulations and a new QI system.