Transition Tax: Heed the IRS Warnings

In 2017, certain taxpayers were subject to a one-time tax on earnings in controlled foreign corporations under Section 965, also known as the transition tax.  Since this was a newly created, one-time tax, it was overlooked or unknown by many taxpayers.  However, for a few reasons, it seems that all applicable taxpayers will soon have […]

IRS Releases Draft International Forms for Partnerships

Despite claims of attempting to simplify compliance, in recent years, forms and compliance for international reporting has become much more detailed and complicated.  In keeping with this theme, the IRS has released drafts of new forms to allow partnerships to report international items to partners with greater detail. At first glance, for many taxpayers it […]

IRS: USMCA Replaces NAFTA in U.S. Tax Treaties

Once it enters into force, the USMCA will replace NAFTA.  Since many U.S. tax treaties make reference to NAFTA, it was unknown if this would cause any issues with these provisions, and despite a recent IRS clarification, it is probably still a bit unknown. References to NAFTA appear in treaties even outside the U.S., Mexico, […]

New NOL Rules and the Transition Tax

Between the Tax Cuts and Jobs Act and the coronavirus, there have been many unique tax situations lately.  It was only a matter of time before these started to interact and cause problems.  As part of the coronavirus provisions under the CARES Act, the IRS allowed for certain NOLs to be carried back.  This carryback […]

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