September 2019

Final regs address partnership’s allocation of creditable foreign tax expenditures

The IRS recently issued final regulations on the operation of a safe harbor rule that’s used in determining whether allocations of partnership creditable foreign tax expenditures to partners are deemed to be in accordance with the partners’ interests in the partnership. This article discusses some notable areas affected by the final regs.

Full Article

IRS issues Q&As on Section 965 transfer and consent agreements

Under Internal Revenue Code Section 965, U.S. shareholders pay a “transition tax” on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States. This article covers some important points made about the tax in recently issued Q&As from the IRS.

Full Article

Six issues targeted in IRS compliance campaigns

The IRS’s Large Business and International Division recently announced six new compliance campaigns. They target S corporation built-in gains taxes, the Offshore Voluntary Disclosure Program, expatriates, high-income nonfilers, erroneous refundable credits of U.S. territories’ filers and deferred compensation. This article takes a look at each.

Full Article