International Tax Blog

Recent Regulation Packages Related To International Tax

Since TCJA, the Treasury Department and the IRS have published thousands of pages of regulations. I have not been able to keep up with the international portions of all those regulation packages. To identify regulation packages that I need to focus on, I have created a web page that lists the recent regulation packages relating to international tax. This page then links to individual regulation package pages. Each separate page includes summary information about the... Read more →

2022 3rd Quarter Published Expatriates

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2022. The number of published expatriates for the quarter was 750. See the chart below for the quarterly expatriates from 2011 to the third quarter of 2022. The 8-quarter moving average has how now dipped down to roughly 750 names per quarter (which is the number of names published... Read more →

2023 Inflation Adjustments for Individuals in the International Tax Arena

This week the IRS published Revenue Procedure 2022-38, setting forth inflation adjusted items for 2023. In the international arena, some of the important inflation adjustments include: $190,000 --- Code § 877(a)(2)(A) --- The average annual net income tax that must be imposed for the five taxable years ending before the date of the loss of United States citizenship (or cessation of long-term permanent residency) for an individual to be considered a “covered expatriate” under Code... Read more →

New IRS Practice Unit – FBAR (FinCEN Form 114)

Yesterday the IRS published a new practice unit discussing the FBAR. This new practice unit has been added to our Practice Units By Topic page. Read more →

How inaccurate is the IRS Version of the Sweden Treaty (pretty inaccurate)

The IRS publishes PDF files of the income tax treaties that the U.S. has entered into with other countries. I don’t usually use the IRS versions of the treaties. I have previously noted inaccuracies in them. In addition, the IRS versions do not incorporate the protocols into the main text of the treaty. However, a client recently had a question about the Sweden-U.S. Income Tax Treaty and had emailed me a copy of the IRS... Read more →

Reviewing Form 5471

When I review a Form 5471, I look for many different things. I created a chart that describes some of the high-level things I look for with respect to each schedule on Form 5471. The chart can be found here. Read more →

16 New Charts Published

Today we published 16 new situational tax charts to AndrewMitchel.com. We have over 1300 charts for FREE on our website. The recently published charts include: TBL Licensing LLC (Gain Recognized on the Transfer of Intangible Property in an Oubound F Reorganization) Rev. Rul. 67-12 (Business Expenses Paid In a Year After the Termination of the Business Were Deductible) Reg. 1.861-9 and -9T (Interest Expense Allocation Example With An Individual Owning Partnerships) Cheat Sheet: 1.861-9 and... Read more →

New IRS Practice Unit - IRC 958 Rules for Determining Stock Ownership

Yesterday the IRS published a new practice unit titled “IRC 958 Rules for Determining Stock Ownership.” The direct and indirect ownership rules in Code §958 are important for purposes of determining, among other things: Whether a U.S. person is a U.S. shareholder of a foreign corporation (Code § 951(b)), Whether a foreign corporation is a controlled foreign corporation, (“CFC”) (Code § 957(a)), Whether a person is related to a CFC (Code §954(d)(3)), and Whether the... Read more →

13,000 Regulation Examples

I often use Cornell’s Legal Information Institute (“LII”) to access tax regulations. I noticed that the HTML on the LII website included regulation examples in

tags with a class of “example”. I thought it would be interesting to extract the text of all of the examples in the regulations and perform some analysis on those regulation examples. Below I describe how I located over 13,000 examples in the tax regulations. My first step was... Read more →

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: [A]s a logical matter, [the taxpayer’s] receipt of the TBL GmbH stock in exchange for the transferred intangible property was a precondition to [the taxpayer’s] distribution of that stock * * *. The distribution could not have occurred until the exchange of property for stock... Read more →

Famous Tax Quotes - One Cannot Distribute What One Does Not Have

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: [A]s a logical matter, [the taxpayer’s] receipt of the TBL GmbH stock in exchange for the transferred intangible property was a precondition to [the taxpayer’s] distribution of that stock * * *. The distribution could not have occurred until the exchange of property for stock... Read more →