International
New Form 5472 Filing Requirement for U.S. Disregarded Entities Owned by a Foreign Person
On December 13, 2016, the IRS issued new regulations (T.D. 9796) that requires U.S. disregarded entities owned by a foreign…
New Controlled Foreign Corporation Constructive Ownership Rule
The Tax Cuts and Jobs Act enacted in December 2017 changed a constructive ownership rule that determines whether a foreign…
Avoid Penalties Related to International Tax Filings
The IRS Large Business and International Process Unit (LB&I) issues internal practice guidance from time to time regarding U.S. international…
Commercial Service Spotlight –Going Global Strategically
At a glance: Main takeaway: Are you a small business or startup with plans for global expansion, but not sure…
Look-Through Rule Under I.R.C. Section 954(c)(6) Is Extended
The President signed The Tax Increase Prevention Act of 2014 on December 19, 2014. The new Public Law No. 113-295 (H.R….
Anti-Deferral and Controlled Foreign Corporations
Based on the general rule of deferral, a U.S. shareholder of a foreign corporation defers U.S. federal taxation on earnings…
IRS Continues to Target Interest Expense Deductions on Intercompany Debt
Tyco International Ltd. filed a case in the US Tax Court in August 2013, in which the company asserted that…
IRS Rules that Mexican Land Trusts are Not Foreign Trusts for Tax Purposes
On June 6, 2013, the IRS issued Revenue Ruling 2013-14, in which it found that Mexican Land Trust (“MLT”) arrangements…
Offshore Voluntary Disclosure Program Still Open for Quiet Disclosures and Formal Disclosures
In January 2012, the IRS extended the Offshore Voluntary Disclosure Program. The program allows U.S. taxpayers to pay penalties and…