LTD Tools

The International Tax section is a compilation of alerts and articles written by members of the ICPAS Taxation International Committee as well as links to websites and other resources of interest to the International tax community. Follow the links below for more information on these topics.  

International Tax Committee Articles

  • New Regulations Require Foreign-Owned Domestic Disregarded Entities to File Form 5472

  • Micro-Captive Insurance

  • Final Section 987 Regulations Provide Guidance to Certain Qualified Business Units

  • Disregarded entities required to comply in new proposed regulations to section 6038A

  • IRS Publishes New Form W-8BEN-E Withholding Certificate with Expanded Treaty Benefits Claim

  • IRS Issues Rules on New Federal Inheritance Tax

  • Legislative Changes Require Captive Insurance Companies to Immediately Assess Their Operations

  • Taxpayers Forces to Allow Production of Foreign Back Account Records

  • IRS Can Now Revoke Your Passport If You Owe Them Money

  • IRS Tweaks Corporate Tax Inversion Rules

  • Proposed Regulations Eliminate 367 Goodwill Exception

  • Surface Transportation Act of 2015: Tax Provisions

  • Short-term Obligation Exception Didn't Apply to CFC's Loans to U.S. Parent

  • District Court Explores Proper Review of FBAR Penalty Issues & Largely Rules Against Taxpayer

  • U.S. Companies Doing Business in Canada

  • Problems Remain with the IRS Offshore Voluntary Disclosure Program

  • IRS Explains Level of Lending & Underwriting Activities That Give Rose to U.S. Trade or Business

  • Documentation Requirements for Related-Party Debt Instruments Under Proposed Section 385 Regulations