August 31st, 2019 by Kim Chen
The IRS has released final regulations on determining the amount of Global Intangible Low-taxed Income (GILTI) included in the gross income of certain U.S. shareholders of foreign corporations, including U.S. shareholders that are members of a consolidated group. The final regulations also address the determination of a U.S. shareholder’s pro rata share of a controlled […]
August 6th, 2019 by Kim Chen
The IRS is encouraging individuals with expiring Individual Taxpayer Identification Numbers (ITINs) who expect to have a filing requirement in 2020 to start the renewal process early to avoid refund delays next year. ITINs that haven’t been used on a return at least once in the last three consecutive years will expire 12/31/19. Also, ITINs […]
January 21st, 2019 by Kim Chen
: Under IRC Sec. 965, which was added by the Tax Cuts and Jobs Act (TCJA), U.S. shareholders of a specified foreign corporation are subject to a deemed repatriation tax. This is accomplished by increasing the foreign corporation’s Subpart F income by the greater of (1) the accumulated post-1986 earnings and profits of the corporation […]
October 17th, 2018 by Kim Chen
Information Letter 2018-0028 In an Information Letter, IRS has advised a taxpayer, who sold his interest in a passive foreign investment company (PFIC), on the steps he can take to verify that he properly reported his PFIC transaction and, presumably, determine whether he is due a refund. Background. A PFIC is any foreign corporation if: […]
August 10th, 2018 by Kim Chen
The IRS has released proposed reliance regulations (REG-107892-18) on the new Qualified Business Income (QBI) deduction under IRC Sec. 199A. The proposed regulations are divided into six substantive sections and provide guidance on calculating the deduction and applying various antiabuse provisions. The IRS also has issued Notice 2018-64 , which proposes a revenue procedure that […]
December 21st, 2017 by Kim Chen
IR-2017-199, Dec. 5, 2017 WASHINGTON— The Internal Revenue Service reminds taxpayers with expiring Individual Taxpayer Identification Numbers (ITINs) to submit their renewal applications as soon as possible. Failing to renew them by the end of the year will cause refund and processing delays in 2018. The IRS mailed letters over the summer to more than […]
December 19th, 2017 by Kim Chen
On December 15, the Conference Committee—having reconciled and merged the differing House and Senate provisions into a single piece of legislation—released the final version of the “Tax Cuts and Jobs Act,” a sweeping tax reform proposal. This article describes key tax changes affecting foreign income and foreign persons, including the exemption from U.S. tax for […]
February 8th, 2017 by Kim Chen
Final regulations (TD 9806) were issued that provide guidance on who is an owner of a PFIC, the annual filing requirements for shareholders of PFICs, and statements required to be filed with the IRS by those excepted from certain foreign corporation return rules. Under IRC Sec. 1297(a) , a PFIC is any foreign corporation if […]
January 20th, 2017 by Kim Chen
The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 changed the due date for filing FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) to April 15 of the following calendar year, with a six-month extension to October 15 allowed. (Previously, the due date was June 30 of the following calendar […]
December 12th, 2016 by Kim Chen
The IRS is encouraging individuals with expiring Individual Taxpayer Identification Numbers (ITINs) to start the renewal process before year-end to avoid delays at tax time. ITINs are issued by the IRS to individuals with a federal tax filing or reporting requirement who don’t have and aren’t eligible to obtain a Social Security number (e.g., foreign […]
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