June 2019 Newsletter

IRS issues final regs on recognition and deferral of foreign currency gain or loss

In May, the IRS issued final regs on the combinations and separations of qualified business units (QBUs) subject to Internal Revenue Code Section 987. The regs also address the recognition and deferral of foreign currency gain or loss with respect to many QBUs. This article notifies readers of some of the important details involved

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Proposed regs would tax S corporation income otherwise allocable to nonresident alien owners of ESBTs

The IRS has issued proposed regs that would ensure that the income of an S corporation will continue to be subject to U.S. income tax when a nonresident alien is a deemed owner of a grantor trust that elects to be an electing small business trust. This article explores some of the pertinent details.

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Court upholds Freedom of Information Act exemption for IRS

The U.S. Court of Appeals for the Federal Circuit recently handed down a decision in Agrama v. U.S.This article explores the details of the case, which determined whether the IRS satisfied its Freedom of Information Act burden of showing that it had conducted an adequate search for the documents that the taxpayer sought related to her alleged failure to properly report an ownership interest in a foreign corporation.

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