United States
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.
The IRS finalized rules for withholding and reporting U.S. source payments to foreign individuals and financial institutions.
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.
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.
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.
New IRS cryptocurrency guidance provides much needed clarity but may require changes to returns not yet filed.
Proposed rules limit the impact and reduce the reporting burden caused by tax reform changes to CFC ownership rules.
The IRS announced new relief procedures from paying back taxes for certain former citizens who wish to become compliant.
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.
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.
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.