Seattle International Tax Attorney Blog

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The IC-DISC (“Interest Charge Domestic International Sales Corporation”) has been a powerful tax incentive supporting US businesses who sell products which are ultimately exported. As the fiscal cliff drama unfolded toward the end of 2012, many in the international tax community wondered whether IC-DISC benefits remain. Thankfully...

FATCA, New Reporting Requirements for Offshore Accounts

Enacted as part of the 2010 HIRE Act, The Foreign Account Tax Compliance Act (“FATCA”) is an important development in U.S. efforts to improve tax compliance involving foreign financial assets and offshore accounts. FATCA’s approach to foreign financial account compliance is twofold. First, U.S. taxpayers with...

RECENT TAX CUTS AND JOBS ACT ARTICLES

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IRS Publishes Guidance on Application of Section 965 for 2017 Tax Year Filings

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The Interest Charge Domestic International Sales Corporation ("IC-DISC") after the Tax Cuts and Jobs Act

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International Tax Law Changes - A Look at the CFC Attribution Rules after the Tax Cuts and Jobs Act 

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RECENT INTERNATIONAL TAX ARTICLES

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Court Reviews Reasonable Cause Standard in Recent Case

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Willful FBAR Penalty Against Taxpayer Sustained

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FBAR Penalty in Excess of $100,00 allowed where multiple counts of FBAR violations

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IRS Announces New Voluntary Disclosure Program for Delinquent International Filings and Foreign Bank Accounts

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FBAR Penalty Does Not Terminate at Death

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IRS Provides Guidance on Standard for Definition of Willfulness under FBAR

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IRS to end Offshore Voluntary Disclosure Program "OVDP"

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Definition of "Willful" in FBAR and OVDP Context Examined by Recent Court Case

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Streamline Offshore Filing Procedure - Application of the Non-Residency Rules to Taxpayers with Foreign Bank Accounts

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Tax Court disallows Section 911 Exclusion due to late filing

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Key Differences Between FBAR & FATCA Filing Requirements

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Tax Court Revisits Definition of "Abode" under Section 911 in Recent International Tax Case

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PFIC Filing Requirements, Who Must File PFIC Form 8621 & For What Tax Years

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UPCOMING AND RECENT INTERNATIONAL TAX PRESENTATIONS

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University of Washington - UW T523 - International Estate Planning

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Panelist: Washington Society of Certified Public Accountants, International Tax Conference 2018

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Panelist: Foreign Personal Holding Company Income Reporting: Mastering Subpart F Inclusions and Deemed Dividend Rules​

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Panelist: Form 8621 PFIC Reporting: Navigating the Highly Complex IRS Passive Foreign Investment Company Rules

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Presentation: Basics of International Tax Planning​ for Attorneys and CPAs

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Bloomberg BNA: International Taxation of Computer Software under Reg. Sec. 1.861-18 & Cloud Computing Transactions

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UPCOMING AND RECENT INTEREST CHARGE DOMESTIC INTERNATIONAL SALE CORPORATION (IC-DISC) PRESENTATIONS

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University of Washington - International Estate Planning - Tax LLM Program - UWT523 

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IC-DISC Tax Planning - Estate Tax Benefits - Estate Planning Council Presentation

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IC-DISC: Tax Law Challenges

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Bloomberg BNA - How to Reduce Tax Obligations Using IC-DISCs - for attorneys and CPAs

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IC-DISC Tax Planning - Life after Summa Holdings v. Commissioner

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Panelist: IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Federal Tax Savings

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