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Eversheds Sutherland (US) LLP

IRS re-commits to pre-filing agreements

On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more

McDermott Will & Schulte

IRS Roundup February 17 – March 14, 2025

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Proskauer Rose LLP

UK Tax Round Up - February 2025

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Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

DLA Piper

France - VAT: New French Administrative Guidelines - Regularisation of Incorrectly Invoiced VAT - Monthly Indirect Tax Alert –...

DLA Piper on

The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more

McDermott Will & Schulte

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

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A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

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The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: U.S. Tax Reporting for Americans That Live Overseas and Voluntary...

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Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more

Miller Nash LLP

Today in Tax: Three Things to Watch for in 2023

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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Like clockwork, Americans greet each new year with soon-forgotten resolutions and unfounded predictions for the upcoming year. In keeping...more

Freeman Law

International Tax Withholding | Chapter 3 of the Internal Revenue Code

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One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Freeman Law

Country-by-Country Reporting

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In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

Freeman Law

The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with...

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The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts. The IRS has just released Notice 2022-36 which provides an...more

Miller Nash LLP

Today in Tax: Three Questions You Should Be Asking If You Have Overseas Affiliates

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US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

Miller Nash LLP

Today in Tax: New Positions on Taxation of “Staking” Rewards; New Reporting Requirements for Foreign Tax Matters

Miller Nash LLP on

Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards - While the IRS has not specifically addressed the taxation of staking rewards, they have indicated a willingness to treat these rewards in...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

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Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.  Generally, there is nothing nefarious about these types of arrangements.  Rather,...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

How to Successfully Request IRS Penalty Relief

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Federal tax penalties have always been an IRS priority.  But, perhaps more so today than three decades ago.  For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion.  Compare that...more

Freeman Law

The Tax Court in Brief - January 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

Foodman CPAs & Advisors

Treasury and IRS are Aiming to Provide Greater Clarity on International Tax Reporting

On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

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