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The article discusses the different important aspects of the Foreign Account Tax Compliance Act (FATCA), which is a major component of the push of the U.S. federal government for increased tax compliance among taxpayers with foreign accounts in the U.S. It says that FATCA is part of the Hiring Incentives to Restore Employment (HIRE) Act. According to the author, the possible effect of FATCA on U.S. taxpayers with foreign assets and accounts is difficult to overstate. According to the author, FATCA imposes a second filing requirement on U.S. taxpayers with foreign assets and accounts. The required components of a FATCA disclosure are also mentioned. INSET: EXECUTIVE SUMMARY.

The article examines the laws governing the taxation of the foreign corporation earnings and profits (E&P) in the U.S. Topics discussed include U.S. federal income tax purposes; the provisions for foreign profit earning as per the U.S. Inernal Revenue Code; and importance of a foreign corporation's E&P in the U.S. taxation of international operations.

The article focuses on how attorneys can accommodate foreign bank and financial accounts (FBAR) filing obligations in the U.S. in 2014. Topics include the civil and criminal penalties for failure to report income, the scope of reporting requirements, and the impact of entity classification on filing obligations.

The article discusses the collaboration of the U.S. Internal Revenue Service (IRS) and the Department of Treasury to propose regulation on corporate tax inversions to prevent certain uses of controlled foreign corporations. Details to the provision includes the use of hopscotch loans, prevention of decontrolling strategy and strengthen the requirement for foreign investment. An overview of the IRS notice is also noted.

The article focuses on the taxation of exchange traded notes (ETNs) in the U.S. It cites that ETNs should be treated as a prepaid forward contract in which the change in the value is taxed only upon sale or redemption and at that time as capital gain or loss. It compares the ownership and tax treatment of ETN with exchange traded funds (ETFs) structured as regulated investment companies (RICs). The Internal Revenue Service (IRS) ruled that a foreign-currency-based prepaid forward contract is taxed as debt for tax purposes under the Revised Rule 2008-1.

The article focuses on various withholding tax issues concerning foreign investments in the U.S. Section 1446 of the Tax code requires foreign or domestic partnership that has U.S. effectively connected taxable income (ECTI) allocated to a foreign partner to withhold and pay U.S. tax. Every partnership that has effectively connected gross income for the partnership's tax year to one or more of its foreign partners must file the IRS Form 8804, Annual Return for Partnership Withholding Tax.

The article focuses on the opportunities provided by the check box rules to tax payers and advisers in tax planning and tax compliance simplification. The approach offers U.S. shareholders of foreign entities flexibility and certainty. It cites the advantages provided by the check-the-box election to U.S. flow-through entities that have foreign operations. It highlights the need for taxpayers and their advisers to be fully aware of the requirements necessary to receive preferential dividend treatment.

The article talks about tax-related issues. As a general rule, if property is transferred by gift, credit claimed by the donor with regard to such property will be subject to recapture, depending on the length of the donor's holding period. Taxpayers may choose between the per country or the overall limitation on foreign tax credit under Code Section 904. It also tackles installment reporting by dealer and optional payment terms. The use of escrow shares in corporate reorganizations is also discussed. It also considers the topic on tax liability of subsidiary withdrawing from group.

The article informs that the U.S. Internal Revenue Service (IRS) has issued final regulations requiring specified domestic entities to report specified foreign financial assets in which they have interests. It mentions that the U.S. Foreign Account Tax Compliance Act (FATCA), requires individuals to report interests in specified foreign financial assets (SFFAs) when filing their federal income tax returns for tax years beginning after March 18, 2010.

The article discusses the changes made by the U.S. Internal Revenue Services (IRS) to its Offshore Voluntary Disclosure Program (OVDP) as of February 2015. Topics discussed include use of OVDP by taxpayers to avoid criminal prosecution by disclosing foreign financial accounts; changes in the procedure for taxpayers who have failed to file required international information returns; and streamlined filing compliance procedures in the U.S.

The article reports the Notice 2014-51 issued by the U.S Internal Revenue Service regarding the amendment of the Section 1298(f) regulations of the Internal Revenue Code to impose filing exemption for U.S holders of marked-to-market passive foreign investment company (PFIC) stock. It mentions the regulations issued by IRS on the application of reporting requirements to shareholders of a PFIC on December 31, 2013.

The article focuses on he introduction of the U.S. Internal Revenue Service's (IRS) anti-abuse rules governing 'Killer B' transactions, which are cross-border triangular reorganizations of foreign corporations. Topics include the repatriation of foreign subsidiary earnings, distribution and contribution rules, and the taxation of controlled foreign corporations (CFCs).

The article reports on the introduction of the U.S. Foreign Account Tax Compliance Act (FATCA) transition period in 2014 and 2015. Topics include withholding agent rules, the taxation of foreign financial institutions (FFIs), and good faith. Information is provided on the amendment of FATCA regulations.

The article focuses on the U.S. rules governing foreign income taxation and taxpayers. Topics include the taxation of multinational enterprises (MNEs), the global allocation of profits, and the oversight of the Organisa­tion for Economic Co-operation and Development (OECD). Information is provided on enterprise resource planning (ERP).

The article focuses on the filing of protective claims after the redetermination of foreign tax liability in the U.S. in 2014. Topics include the ten-year period of limitation, the expiration of the refund statute, and the U.S. Internal Revenue Service's (IRS) discretion in determining the processing and approval of protective claims.

The article focuses on the efforts of multinational companies in the U.S. to hold large unrealized built-in-gains in their foreign investments, attributable to the devaluation of the U.S. dollar. It cites an example of such situation. The effect of Code sections and affiliated regulations may minimize the taxability of the gain on recognition of companies. The exchange fluctuations due to change in value of the U.S. dollar could result in unexpected profitability on transactions involving disregarded and corporate entities.

The article discusses a case which dealt with the regulation on interest paid to related foreign persons. The U.S. Internal Revenue Service determined that the Illinois-based corporation acquired by a French corporation had a tax deficiency and the corporation challenged the deficiency in Tax Court by arguing that it should be allowed to deduct the loan in which the interest accrued. It provides an overview of the Regulations Section 1.267(a)-3 used in the case. In analyzing the validity of the regulation, the court must determine whether the plain meaning of the relevant Code provisions either supports or opposes the regulation.

The article focuses on the U.S. Internal Revenue Service's (IRS) release of final regulations on withholding and reporting by foreign financial institutions (FFIs) under the Foreign Account Tax Compliance Act of 2009 (FATCA). Topics include taxation on payments made to nonfinancial foreign entities (NFFEs) and the U.S. Hiring Incentives to Restore Employment Act of 2010.

Discusses the application of Section 512(b) of the Tax Simplification and Technical Corrections Act of 1993 on deemed and actual dividends paid to a US tax exempt entity by a foreign subsidiary. Accounting and tax treatment of deemed and actual dividends distribution; Proposal from the US Congress' House and Ways Committee to narrow down the language of the law to specifically target captive insurance industry.