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Brutal Results for Foreign Corporation That Failed to File US Tax Returns

March 2, 2021

US Tax Court disallows all deductions for UK company operating in the US on the Outer Continental..

LB&I Division Extends Relaxed Document Request Guidelines

February 9, 2021

Continued suspension of IDR procedures offer you additional time to respond to an agent’s request..

How Are COVID-19 and a PFIC Similar?  Nobody Wants Either One!

February 2, 2021

If you have invested in any foreign corporations, you may be aware that you want to avoid having..

TAX EXTENDERS: LOOK-THROUGH RULE FOR CFCs EXTENDED!

December 28, 2020

Although the provision that allows for the deduction for expenses paid with PPP loan proceeds and..

MOVE OVER FBAR REPORTING: FinCEN WANTS US COMPANIES TO REPORT ON THE BENEFICIAL OWNERSHIP OF US COMPANIES!

December 11, 2020

US companies may already be familiar with the requirements to report ownership of foreign bank..

TITLE TRANSFER ON FOREIGN SALES: TIME TO CHANGE BACK TO THE US?

December 8, 2020

It used to be common for US taxpayers to transfer title to product sales destined for a foreign..

TWO NEW INTERNATIONAL TAX COMPLIANCE CAMPAIGNS ADDED TO IRS ACTIVE LIST

December 1, 2020

The IRS Large Business and International (LB&I) Division recently added four new compliance..

FOREIGN TAX REDETERMINATIONS = MORE AMENDED RETURNS

November 24, 2020

Foreign tax redetermination (FTR) regulations have been modified (or finalized) for 2020. A FTR..

FINAL DOWNWARD ATTRIBUTION OWNERSHIP REGULATIONS DID NOT ELIMINATE “THE MISTAKE”

October 20, 2020

Most international tax professionals and the IRS believe Congress made a mistake (“The Mistake”)..

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