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AbitOs (Formerly LLLGPA) | International Tax Newsletter | August 2020

August 24, 2020
Newsletter - August 2020
Dear Client
We hope this email finds you and your family in good health. Please enjoy our August Newsletter with very interesting topics!

District court: FBAR non-willful penalty applies per report, not per account

A U.S. District Court recently concluded that the penalty for a non-willful violation of the rules relating
to FinCEN Report 114, “Report of Foreign Bank and Financial Accounts” — commonly referred to as an FBAR — applies to each report rather than to each foreign financial account maintained but no timely or properly reported. Let’s take a closer look at the details.

Final regs on deduction for foreign-derived intangible income and GILTI

The IRS recently issued final regs that cover determining the amount of the tax deduction for foreign derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. They retain the basic approach and structure of the proposed regs, with certain revisions. Here are some highlights.

COVID-19 relief available to some nonresident aliens and foreign corporations

On its website, the IRS recently announced tax relief for nonresident aliens and foreign corporations
that don’t have a U.S. trade or business (USTB) because of travel disruptions related to the COVID-19 pandemic. This includes partnerships in which nonresident aliens and foreign corporations are partners. Read on for further details.
This publication is distributed with the understanding that the author, publisher and distributor are not rendering legal, accounting or other professional advice or opinions on specific facts or matters, and accordingly assume no liability whatsoever in connection with its use. ©2019 • ITMOct19
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