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Searching Content indexed under Income Tax by David E. Sites ordered by Published Date Descending.
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Tax Court Ruling On Redemption Of Partnership Interest By Foreign Partner May Allow For Refund Opportunity
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that certain gain recognized by a nonresident partner...
United States
22 Aug 2017
2
Rejecting A Revenue Ruling, Tax Court Rules That Foreign Partner Is Not Subject To U.S. Tax On Redemption Of Partnership Interest
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that gain recognized by a nonresident partner...
United States
16 Aug 2017
3
Treasury Identifies Eight Regulations Subject To Modification And Potential Repeal
The Treasury Department on July 7 issued Notice 2017-38 which identifies eight regulations — including those issued under Section 385 — that could be subject to some reform, including modification...
United States
21 Jul 2017
4
IRS Issues Regulations Limiting Creditability Of Foreign Income Taxes Following Covered Asset Acquisitions
On Dec. 6, 2016, the IRS and Treasury issued temporary (T.D. 9800) and proposed (REG-129128-14) regulations under Section 901(m).
United States
30 Jan 2017
5
FinCEN Extends General Filing Deadline For FBARs, Continues Yearly Extension For Certain Individuals
The new annual due date for filing Form 114, Report of FBAR for foreign financial accounts is April 15 with a maximum extension for a six-month period ending on Oct. 15.
United States
24 Jan 2017
6
Officials Provide Update On International Guidance Projects
On Sept. 30, officials from Treasury and the IRS provided an update on a number of guidance projects relating to international tax.
United States
18 Oct 2016
7
IRS Announces Regulations Identifying Two New Foreign Tax Credit Splitter Arrangements
The IRS has announced forthcoming regulations (Notice 2016-52) under Section 909 dealing with foreign tax credits after a foreign adjustment.
United States
4 Oct 2016
8
IRS Adds New International Projects To Priority Guidance Plan
The IRS has added and modified several international guidance projects in the 2016‒2017 Priority Guidance Plan.
United States
4 Oct 2016
9
Final Regulations Issued On U.S. Government Foreign Procurement Payments
The IRS recently released final regulations (T.D. 9782) under Section 5000C relating to the 2% tax on payments made by the U.S. government to foreign persons pursuant to certain contracts.
United States
4 Oct 2016
10
Ninth Circuit Holds Online Gambling Accounts Not Subject To FBAR Reporting
The Ninth Circuit Court of Appeals held on July 26 that a taxpayer was not required to report certain online gambling accounts to the IRS...
United States
22 Aug 2016
11
IRS Issues Final Regs On BEPS Country-By-Country Reporting
The IRS issued final regulations on June 29 that will require U.S. multinationals with more than $850 million in revenue to report specific information on a country-by-country basis for the first time.
United States
21 Jul 2016
12
European Union Reaches Political Agreement On Anti-Tax Avoidance Directive
The political agreement on the Directive is expected to be submitted to ECOFIN on July 12 and will likely be formally adopted without further discussion.
European Union
12 Jul 2016
13
Treasury Issues Regulations Targeting Inversions And Related-Party Debt Transactions
The IRS and Treasury on April 4 announced their latest action to limit inversion transactions and address earnings stripping.
United States
20 Apr 2016
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