Letter Ruling Conjures Ghost of Section 958(b)(4) Past
Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions
What’s Your Source? Proposed Regulations on Sourcing Inventory Sales
Is your inventory sales income U.S. or foreign source? Well, it depends. In case you missed it, our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax Cuts and Jobs Act.
Place of production now determines source for sales of produced inventory
Coordinating Section 863(b) and Section 865 for sales through an office
The overlap of Section 865(e)(2) and Section 864(c)(4)(B)(iii) for certain “nonresidents”
Read the full advisory here. [...]Read more
Federal Circuit Court of Appeals Weighs In on Willful FBAR Penalties
Recently, a federal appellate court ruled in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as required under the Bank Secrecy Act. Our International Tax Group discusses:
Federal Circuit rules in favor of the IRS, upholding higher statutory ceiling
Lower courts have split on the issue
What’s next?
Read the full advisory here. [...]Read more