As a reminder, U.S. citizens, resident aliens and any domestic legal entity with foreign financial accounts must file their annual Report of Foreign Bank and Financial Accounts (FBAR) by April 15, 2023. Who Must File? The Bank Secrecy Act (BSA) manda...

The Internal Revenue Service (IRS) recently shared new FAQs outlining the scope of filing relief for domestic entities that must follow new international reporting requirements. The FAQs come after the IRS’ Feb. 15 announcement stating it will prov...

Non-resident businesses and digital platform operators (i.e., online marketplaces) selling goods and services online in Canada will need to comply with the new GST/HST rules for e-commerce activity, beginning July 1, 2021. These new rules generally a...

The Internal Revenue Service (IRS) Large Business & International (LB&I) division recently updated its active list of compliance campaigns with four new campaigns. Two of these campaigns may impact international taxpayers, so it is imperative...

Many international tax professionals believe that Congress made a blunder (“The Mistake”) when it repealed Sec. 954(b)(4) in the 2017 Tax Cuts and Jobs Act (TCJA). While intending to punish expatriated U.S companies, it actually brought foreign c...

Recently, the Internal Revenue Service (IRS) updated Publication 5118 to reflect new changes made to the Foreign Account Tax Compliance Act (FATCA) Online Registration System for sponsored entities. Given these new changes, now may be an opportune ti...

After requests for more guidance, the Internal Revenue Service (IRS) recently issued final regulations on the base-erosion and anti-abuse tax (BEAT). These final regulations were created to finalize (with a few changes) the additional proposed regula...

Recently, there have been changes that may eliminate some of the deemed distributions from controlled foreign corporations (CFCs) for U.S. shareholders. As a result, the number of forms and the complexity in completing them is expected to be reduced....