Category: International Tax

International Tax

Hurricane Helene Victims Receive Relief for Filing Annual Reports of Foreign Bank and Financial Accounts (FBAR) by Arthur J. Dichter, JD, LLM, TEP


Posted on October 07, 2024 by Arthur Dichter

The Financial Crimes Enforcement Network (FinCEN) today postponed the 2023 Report of Foreign Bank and Financial Accounts (FBAR) filing deadline from Oct. 15, 2024, to May 1, 2025, for taxpayers who live in federally designated disaster areas in the wake of Hurricane Helene. This six-and-a-half-month filing extension applies to qualifying taxpayers in Alabama, Georgia, North […]

Recent Court Rulings Uphold Congressional Authority to Assess Taxes and Penalties on U.S. Taxpayers with Foreign Interests by Andrew Leonard, CPA


Posted on September 12, 2024 by Andrew Leonard

The IRS scored significant wins in two separate cases before the U.S. Supreme Court and D.C. Court of Appeals. While both matters addressed different provisions of the tax code, the court’s decisions essentially fortified the IRS’s international reach and its ability to enforce compliance with various U.S. tax laws regarding taxpayers’ foreign investments and business […]

IRS Updates Guidance Related to Foreign Gains and Losses Under Section 987 by Jairan Shirazi


Posted on August 07, 2024 by Jairan Shirazi

One of the more challenging tax reporting requirements for multinational businesses is the translation of gains and losses of their foreign branch offices and qualified business units (QBUs) into their home country’s functional currency. This process is often complicated by exchange rate fluctuations, including currency devaluations, that can have a material impact on the principal […]

Stricter Reporting Requirements Create Planning Opportunities for Foreign Trusts by Joel G. Young, JD, LLM


Posted on August 06, 2024 by Joel Young

In May 2024, the IRS issued proposed regulations concerning the reporting requirements and tax consequences of U.S. persons who create, fund, transact with and receive gifts or loans from foreign trusts. The guidance, which applies to Sections 643(i), 679, 6039F, 6048, and 6677 (the foreign trust and gift provisions) of the U.S. tax code, updates […]

U.S. Taxpayers Living Abroad May Have Opportunities to Claim Tax Refunds for Foreign Tax Credits Applied Against Net Investment Income Tax by Andrew Leonard, CPA


Posted on July 17, 2024 by Andrew Leonard

A recent decision by the U.S. Court of Federal Claims may open the door to a potential deluge of requests for tax refunds from U.S. citizens and resident aliens living or working in foreign countries with which the U.S. has an income tax treaty. In Christensen v. United States, the court interpreted the U.S.-France Income […]

FASB Approves More Detailed Income Tax Reporting Standard for Public and Private Companies by Brent Leslie, CPA


Posted on October 31, 2023 by Brent Leslie

The Financial Account Standards Board (FASB) recently voted to approve a new accounting standard that will require U.S. businesses to disclose significantly more details about their global income tax liabilities beginning as early as 2025. The move is a part of the FASB’s larger effort to improve the effectiveness of disclosures in the financial statement […]

Trends in International Tax Reporting, Failure to File Penalties by Joel G. Young, JD, LLM


Posted on May 02, 2023 by Joel Young

U.S. tax law requires taxpayers to annually report many of their cross-border activities, including the existence of foreign bank accounts, interests in foreign companies and large gifts from foreign persons. While most of these reports are merely informational and have no bearing on taxpayers’ actual U.S. tax liabilities, failing to file the appropriate forms or […]