Social Media Ideas for Controlled Foreign Corporation (Cfc) Rules

IRS eases proposed sovereign wealth fund tax rules

New guidance provides transition relief, grandfathering protection and delayed implementation for taxing income of foreign governments investing in U.S. businesses.

Foreign branch exemption to become mandatory from 2027

The post Foreign branch exemption to become mandatory from 2027 appeared first on LLP Site.

HMRC Consults on Aligning the Taxation of Distributions from Non-UK Resident Companies

How Foreign Investments Can Lead to IRS Penalties That Wipe Out Profits

Global diversification can be a powerful wealth strategy, but without proper tax planning, foreign investments can trigger complex reporting rules and costly IRS penalties that cat...

Treasury Regulation Section 1.951A-2(c)(5) Held Invalid: Court of Federal Claims Rules Against Amortization Denials in P...

Keysight Technologies, Inc. & Subsidiaries v. United States, No. 25-137 (Fed. Cl. July 2, 2026) The United States Court of Federal Claims has held that the Department of...

What will Bill C-31 tax changes mean for your clients?

RSM Canada experts tell WP that expanded CRA powers, anti-avoidance rules and clean economy credits demand immediate strategic attention for businesses, family offices, HNWIs

Tax Planning for Carve-Out and Take-Private Transactions: Use of Selective Section 338 and/or 336 Elections

In carve-out transactions, especially in take-private transactions backed by private equity (PE), tax friction costs can often make or break a deal. By the same token, creative tax...

Relief from Ineffective S Corporation and QSub Elections: An Analysis of PLR 202624006

IRS Private Letter Ruling 202624006, June 12, 2026. The matter involves a series of corporate reorganizations and tax elections concerning several entities, primarily a limite...

Coca-Cola's $20B tax fight reaches federal appeals court this week

Decade-long IRS dispute over foreign profit allocation could reshape multinational tax enforcement

Foreign Assets, Reassessment & Non-Residents: ITAT Special Bench Clarifies the 16-Year Rule

Foreign Assets, Reassessment & Non-Residents: ITAT Special Bench Clarifies the 16-Year Rule The reassessment provisions under the Income Tax Act have always been a fertile grou...

Three Questions to Ask About New Tax Transparency Regimes

The new data disclosures will draw significant attention in 2026 and beyond. However, because the data is rooted in financial accounting concepts, affected by timing issues, and sh...

Technical Analysis of TD 10051: The Reclassification of Abusive CRAT Structures as Listed Transactions

TD 10051, July 9, 2026 The issuance of TD 10051, which finalizes the proposed rules set forth in REG-108761-22, represents a definitive strategic shift in the Internal Reven...

Economic Risk of Loss and Conditional Deficit Restoration Obligations

Chief Counsel Advice Memorandum Number: 202628009, Office of Chief Counsel, Internal Revenue Service (Written: May 29, 2026, Redacted Version Released: July 10, 2026) The ma...

IRS Tightens FBAR Penalties for 2026 - Clear Start Tax Warns Holders of Foreign Accounts to Review Filing Obligations

U.S. taxpayers with foreign bank or financial accounts totaling more than $10,000 at any point during the year are required to file the FBAR - and the penalty schedule for failures...

US Citizen tax form questions for "simple" return

Nunthewiser: If you look at the French form instructions for the 2047 (2047NOT pg 5 ) it reads: UNITED STATES div. 17.6%, int. 17.6% Dividends: Dividends from U.S. sources receive...

Preparing Tax-Exempt Organizations for the New Covered Employee Rules for the Expanded Code §4960 Excise Tax

Final Regulations Modify Information Reporting for Section 751(a) Partnership Interest Exchanges

TD 10048, May 20, 2026 Under section 741 of the Internal Revenue Code (Code), "gain or loss recognized by a transferor partner upon sale or exchange of a partnership interes...