International Tax Blog

Updated IRS Practice Units by Topic Page

The IRS publishes Practice Units (“PUs”) (formerly "International" Practice Units) on its website. PUs provide IRS staff with explanations of general tax concepts, as well as information about specific types of transactions. These PUs discuss many U.S. international tax issues that are applicable to businesses. The IRS website does not categorize them by topic therefore it can be difficult to find PUs on a particular topic. Our page Practice Units by Topic categorizes the PUs... Read more →

New & Updated Draft International Forms

The IRS has published new and updated draft forms. Some of these forms include: Form 965, Inclusion of Deferred Foreign Income Upon Transition to Participation Exemption System (Schedule A, Schedule B, Schedule C, Schedule D, Schedule E, Schedule F, Schedule G, Schedule H) Form 965-A, Individual Report of Net 965 Tax Liability Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations (Schedule E, Schedule H, Schedule I-1, Schedule J, Schedule M,... Read more →

Video - GILTI for a CFC With & Without Debt

Today we uploaded a video discussing 2 Examples of the GILTI: Example 1: CFC Without Debt Example 2: CFC With Debt Read more →

12 New Tax Charts

We recently added 12 new situational charts to andrewmitchel.com (listed in topical order). View these charts and over a thousand other free charts at andrewmitchel.com (listed in alpha-numeric order). Bass (Swiss Corporation Was Respected As a Separate Entity) Rev. Rul. 79-371 (Gift of Installment Note Triggered Gain) Rev. Rul. 80-58, Situation 1 (Rescission of Contract Within Same Taxable Year) Rev. Rul. 80-58, Situation 2 (Rescission of Contract in Following Taxable Year) Rev. Rul. 80-164 (Cash... Read more →

Famous Tax Quotes – New Batboy Changing the Outcome of the World Series

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: [T]o rely * * * on this solitary word change in a different subsection is like hoping that a new batboy will change the outcome of the World Series. United States v. Home Concrete & Supply LLC, 132 S. Ct. 1836 (2012) Read more →

Famous Tax Quotes - That’s How The Cookie Crumbles

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: When filing their amended returns for 2004 and 2005, petitioners made voluntary, irrevocable elections under section 962. * * * By making these elections petitioners got what they bargained for * * * [T]hese elections may ultimately cause them to include more gross income than... Read more →

Video – GILTI in a Minute

Today we uploaded a video that provides a very condensed version (1 minute) of the GILTI calculations. Read more →

GILTI Regulations Preamble: Is a 100 Word Sentence Too Long?

Today the IRS published the proposed GILTI regulations. The preamble to the regulations includes the following sentence: In addition, a requirement that a partnership’s basis in specified tangible property be measured on the last day of a CFC partner’s taxable year could be burdensome for partnerships that have one or more CFC partners with taxable years that do not coincide with the partnership’s taxable year and, in those cases, would have the effect of decoupling... Read more →

13 Charts of Code §958 Regulation Examples

We have created charts of the 13 of the examples included in Treas. Reg. §§1.958-1 and -2. Treas. Reg. §1.958-1 contains 5 examples demonstrating attribution through direct and indirect ownership. These regulations provide a limited form of attribution primarily for use in determining the amount taxable to a U.S. shareholder under Code §951(a) (Subpart F Income). Treas. Reg. §1.958-2 contains 8 examples demonstrating attribution through constructive ownership. These regulations provide that the attribution rules of... Read more →

10 Charts of Sec. 199A QBI Regulation Examples

Last week the IRS issued proposed regulations under Section 199A regarding the qualified business income (QBI) deduction. We have created charts of 10 of the examples included in Prop. Treas. Reg. §1.199A-1(c)(3) and (d)(4). We also created a video discussing the first four examples. See our YouTube channel. The examples include: 1.199A-1(c)(3) Ex. 1, QBI Ded'n, Below Threshold: TI Limit (No CG) Ex. 2, QBI Ded'n, Below Threshold: TI Limit (With CG) Ex. 3, QBI... Read more →