International Tax

IRS Issues New Guidelines on Foreign Currency Gain and Loss Exemptions: What It Means for You

August 22, 2024

The IRS has recently re-proposed important rules that impact how controlled foreign corporations (CFCs) report foreign currency gains and losses. If your business operates internationally, these changes could significantly affect your U.S. tax obligations. What’s New? On Monday, the IRS introduced new regulations under RIN 1545-BM80, REG-111629-23. These rules outline the specific situations in which…

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US Companies Get Temporary Relief from Global Minimum Tax

July 25, 2023

On Monday, July 17th, countries around the world agreed to updated administrative guidance from the Organization for Economic Co-operation and Development (OECD). This new guidance allows countries that have implemented the new global minimum corporate tax (GMCT) additional time to prepare, providing temporary relief for American companies. Background Over the past few decades, technological improvements…

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Foreign Tax Credit Regulations: Recent Updates for Taxpayers with Royalty Income from Abroad

May 30, 2023

If you are an American taxpayer who earns income from abroad, you may already be familiar with the foreign tax credit (FTC). In short, taxpayers who pay taxes to foreign countries for income earned abroad may be able to offset a portion of their tax liability in the US using the FTC. For companies and…

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K2 K3 International Reporting Requirements

March 10, 2022

The IRS has made significant changes this year that will impact many pass-through entities (Partnerships and S Corporations) regarding how they will file their tax returns. In an effort to provide reporting consistency, the IRS created Schedules K-2 and K-3 which add a new level of reporting that many pass-through entities will have to complete.…

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Foreign Tax Credits

February 7, 2022

On November 12, 2021, the U.S. government released an update on how to claim foreign tax credits. Effective with the 2021 tax year, any foreign tax credit can only be claimed on income that meets a jurisdictional nexus test, which means the credits must be claimed on a country-by-country basis. A company looking to claim…

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