August – 2020

District court: FBAR non-willful penalty applies per report, not per account

A U.S. District Court recently concluded that the penalty for a non-willful violation of the rules relating to FinCEN Report 114, “Report of Foreign Bank and Financial Accounts” — commonly referred to as an FBAR — applies to each report rather than to each foreign financial account maintained but not timely or properly reported. Let’s take a closer look at the details.

Read More

Final regs on deduction for foreign-derived intangible income and GILTI

The IRS recently issued final regs that cover determining the amount of the tax deduction for foreign derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. They retain the basic approach and structure of the proposed regs, with certain revisions. Here are some highlights.

Read More

COVID-19 relief available to some nonresident aliens and foreign corporations

On its website, the IRS recently announced tax relief for nonresident aliens and foreign corporations that don’t have a U.S. trade or business (USTB) because of travel disruptions related to the COVID-19 pandemic. This includes partnerships in which nonresident aliens and foreign corporations are partners. Read on for further details.

Read More