On Dec. 13, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations (the Proposed Regulations) that provide certain guidance and relief from the regulatory burden associated with Sections 1471 through 1474 of the Internal Revenue Code (IRC), commonly referred to as Foreign Account Tax Compliance Act (FATCA), as well as with respect … Continue Reading
The Internal Revenue Service recently issued proposed regulations under Section 956 of the Internal Revenue Code (IRC) that may allow foreign subsidiaries of U.S. multinational corporate borrowers to provide additional credit support to lenders without resulting in adverse U.S. federal income tax consequences. Although the proposed regulations may be relied upon by taxpayers for taxable … Continue Reading
The due date for filing 2017 U.S. federal income tax returns for individuals who have requested an extension is Oct. 15, 2018. With only one month left until the deadline, we have prepared a countdown of 10 common tax reporting obligations that may be relevant to global individuals with cross-border assets or activities. 10, 9, … Continue Reading
