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 Seeks Comments on Implementing New Foreign Account Tax Compliance Act; Stakeholders Weigh in

The Internal Revenue Service April 7 asked the tax community for comments on how best to implement provisions of the Foreign Account Tax Compliance Act, recently signed into law under jobs legislation, that require extensive new reporting and disclosure on the ownership of U.S. assets in foreign banks.

ANALYSIS: Foreign Account Tax Compliance: New U.S. Rules Requiring Reporting on Certain Foreign Accounts

This legislation is a direct result of the focus by the United States and other industrialized and developing countries on combating offshore tax evasion and recouping much needed tax revenues.

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…

Foreign Bank Reporting Provisions in New Hiring Law Seen Changing Withholding Landscape

President Obama’s signature on major new jobs legislation (Pub. L. No. 111-147; H.R. 2847) March 18 puts in place a host of requirements for foreign banks to report and disclose accounts with U.S. owners…

IRS Strongly Disagrees with Tax Court Ruling in Container Corp. Foreign Income Case, Weighs Next Steps

The Internal Revenue Service strongly disagrees with the U.S. Tax Court’s recent ruling in Container Corp. v. Commissioner that guaranty fees paid by a U.S. subsidiary to…

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…

BNA INTERVIEW: International Tax Landscape Shaped by Globalization, Shifting Economy, Ex-IRS Official Says

Deborah Nolan, former commissioner of IRS’s Large and Mid-Size Business Division and currently with Ernst & Young LLP, tells BNA that…

Guaranty Fee Payments by U.S. Subsidiary to Mexican Corporation Analogous to Payments for Service, Tax Court Says

The U.S. Tax Court ruled in a Feb. 17 opinion that guaranty fees paid by a U.S. subsidiary to a Mexican corporation are analogous to payments for a service and are not…

U.S. Official Rules out Renegotiation of Accord with Switzerland on UBS Data

The United States is unwilling to renegotiate an agreement with Switzerland under which the Swiss government promised to…

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