GAO Recommends Easing Tax Compliance Requirements for Nonresident Aliens

The federal government could get a better hold on tax compliance for nonresident aliens working in the United States by easing some of its requirements, raising the exemption threshold on U.S.-earned income…

IRS Official Predicts Scrutiny of Offshore Compliance, Transfer Pricing

Transfer pricing, withholding for nonresident aliens, and offshore compliance will be a major focus of scrutiny for the Internal Revenue Service in the global arena, new…

IRS Stressing Focus on Global Examinations, Seeking More Data on Taxpayers, KPMG Says

The Internal Revenue Service is intensifying its approach on audits of international issues, seeking increased information from taxpayers, and amping up not just…

Payments of U.S.-Source Income to Foreign Persons Skyrocketed Between 2005, 2007

Payments of U.S.-source income to foreign persons skyrocketed more than 70 percent between 2005 and 2007, with the vast majority of the payments going…

ANALYSIS: New IRS Audit Guidelines Target Equity Swaps with Non-U.S. Counterparties

For more than 20 years, applicable Treasury regulations have provided that income from an equity swap, including dividend equivalent…

IRS Officials, Stakeholders Discuss Range of Issues on Expatriation, Foreign Trusts

Internal Revenue Service officials and private sector stakeholders Jan. 19 discussed a broad range of international issues related to expatriation…

IRS Finds No Foreign Base Company Sales Income from Transactions involving Bifurcated Manufacture of Products

The Internal Revenue Service in Private Letter Ruling 201002024, released Jan. 15, applied the tax rate disparity test in determining that…

ANALYSIS: Proposed Check-the-Box Modifications for Foreign Entities: Potential Impact in the Context of Foreign Base Company Sales Income

Since 1997, taxpayers have been permitted to make entity classification elections for eligible business entities, including certain foreign entities. These elections became known as “check-the-box” elections and…

U.S. officials discuss permanent establishments in tax disputes

U.S. government officials Dec. 10 expressed dedication to a high permanent establishment threshold while revealing stepped-up efforts to find foreign taxpayers who may have created PEs in the United States…