July 2019 Newsletter

Final regs exclude corporate U.S. shareholders from application of Section 956

The IRS recently issued final regulations that reduce the amount determined under Internal Revenue Code Section 956 for certain domestic corporations that own (or are treated as owning) stock in foreign corporations. This article clarifies the agency’s intention behind the final regs and looks at two important areas of change.

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Proposed regs look to close CFC loopholes

The IRS recently issued proposed regs that would amend the controlled foreign corporation (CFC) related party and CFC active rent rules to close certain loopholes. This article provides some details on each of the loopholes.

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District court refuses to dismiss FBAR penalty action against decedent’s family

If you have an interest in (or authority over) a foreign financial account, you may have to electronically file a “Report of Foreign Bank and Financial Accounts” (FBAR) or face penalties. In the recent case of U.S. v. Park, a federal district court refused to dismiss an action to collect an FBAR penalty from a decedent’s family. This article explores the details of the court’s decision.

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