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Tax Planning › Foreign Earned Income › Income Taxes

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Freeman Law

Tax Court in Brief | Domdom v. Comm’r | Foreign Earned Income and Tax Home for U.S. Income Tax

Freeman Law on

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more

Freeman Law

Foreign Earned Income Exclusion

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U.S. citizens and resident aliens who live abroad are taxed on their worldwide income. But such taxpayers may qualify for the foreign earned income exclusion, which allows certain taxpayers to exclude up to $112,000 (in...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

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The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

McDermott Will & Schulte

Weekly IRS Roundup May 4 – May 8, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

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On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

Foodman CPAs & Advisors

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

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IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

McDermott Will & Schulte

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

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On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

Holland & Knight LLP

Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed...

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• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC). • A foreign corporation...more

Pierce Atwood LLP

Maine Revenue Services Explains IRC § 965 Deferred Foreign Income Taxation

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Maine Revenue Services (MRS) issued guidance and amended the Maine corporate income tax return instructions last week to explain Maine’s conformity to federal taxation of deferred foreign income, also called deemed...more

Fenwick & West LLP

US Taxation of IP After Tax Reform

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Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more

Butler Snow LLP

5 Common Tax Misconceptions Facing U.S. Persons Living Outside the U.S.

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Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more

Foodman CPAs & Advisors

“File before the IRS discovers that you failed to choose the Exclusion”: words of wisdom to US Taxpayers Living Abroad

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If you are a US citizen or a Permanente Resident and you live abroad, you are taxed on your worldwide income and you are considered a US Taxpayer. ...more

Foodman CPAs & Advisors

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

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Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

Foodman CPAs & Advisors

May I continue excluding income earned in a Foreign country after 2017?

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For most Expatriates, very little changes under the Tax Cut and Jobs Act (TCJA) because “foreign earned income” continues to be treated the same way for Individual Taxpayers under the TCJA. For others, provisions of the...more

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