A recent district court case* against the estate of a deceased taxpayer has ruled in favor of the IRS granting over…
Robert EwanisNovember 23, 2020
As part of tax reform initiatives in 2017, Section 965 of the Tax Cut and Jobs Act (TCJA) requires that…
Amanda BrownNovember 3, 2020
Holders of bank accounts outside the United States may be required to file FinCEN Form 114, Report of Foreign Bank…
Vinay NavaniOctober 22, 2020
The Global Intangible Low Taxed Income (GILTI) tax regime was first introduced under the 2017 Tax Cuts and Jobs Act.…
Robert EwanisAugust 20, 2020
On July 23, 2020, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) published in the Federal…
WilkinGuttenplanAugust 20, 2020
The IRS recently announced a new area of focus under its issue-based audit strategy program focusing on Internal Revenue Code…
Lina LadekarlJuly 30, 2020
The Internal Revenue Service (IRS) is continuing to increase its focus on cross border transactions and their reporting requirements. While…
Robert EwanisJuly 17, 2020
The U.S. Small Business Administration (SBA) issued additional guidance on May 18, 2020, clarifying how employees of foreign affiliates are…
Vinay NavaniMay 19, 2020
Just as US corporations must file a US corporate tax return, so must a foreign corporation file a US corporate…
April PengFebruary 26, 2020
