In response to international travel and business disruptions caused by COVID-19, the IRS recently issued Rev. Proc. 2020-30. It provides that certain ‘temporary activities’ will not be considered for the purposes of determining whether a domestic corporation has a foreign branch separate unit…

The Bureau of Economic Affairs (BEA), which provides data on U.S. international trade, has set a deadline of May 29, 2020 or June 30, 2020 (depending on the number of filings) for the filing of two survey forms-- BE-10 and BE-15. The BEA uses information from these surveys to produce periodic…

U.S. individual taxpayers who returned to U.S. due to COVID-19

Under a new IRS rule (Rev. Proc. 2020-27), taxpayers who were living abroad and planned to claim the Foreign Earned Income Exclusion (FEIE) but had to return to the United States as a direct result of the COVID-19 pandemic…

On March 2, 2020, the IRS released Revenue Procedure 2020-17 which exempts certain U.S. citizens and resident individuals who have ownership of or transactions with tax-favored foreign retirement and non-retirement savings trusts from reporting requirements. Taxpayers who qualify for this relief…

Final Rules Released — Along with a Newly Proposed High-Tax Exception

The 2017 Tax Cuts and Jobs Act (TCJA) created a new framework for international taxes, including the concept of global intangible low-taxed income (GILTI), that affects U.S. taxpayers who own stock in foreign…

In today’s global economy, multinational corporations engage in numerous cross-border transactions. But how they report those transactions is often vague. To help minimize stakeholders’ exposure to potential hidden risks, the Financial Accountability & Corporate Transparency (FACT) Coalition…

The Chairman of the Financial Accounting Standards Board (FASB), Russell Golden, states that the global financial reporting project is alive and well. Russell set the record straight and denied rumors that the FASB and the International Accounting Standards Board (IASB) are at odds.

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Did you pay tax on a Section 965 inclusion in 2017? Do you plan to repatriate cash out of the earnings that were taxed under Section 965?

If so, it is important to consider distributing the cash before the end of your 2018 tax year. If you are a calendar-year taxpayer, cash should be…

At this time of year, we prepare a lot of 1065 and 8865 forms for U.S. and foreign partnerships. A common question is when it would be appropriate to file a Form 1065 for a foreign partnership.

Typically, a foreign partnership with U.S. partners would not file a U.S. tax return. Instead…