TIGTA Suggests IRS Follow Transfer Pricing Roadmap

Can Lump Sum Cash Payment Qualify As Alimony?

Transfer pricing is and has been the most significant and difficult issue the IRS audits. The audits are typically closed with the IRS agents proposing unreasonably large adjustments and IRS appeals sustaining a very low percentage of the adjustments. The IRS has not been very successful in litigating transfer pricing cases either. As a result,…

Tax on Nonresident Alien Gambling Winnings

Are non-resident aliens who receive gambling winnings while visiting the U.S. able to deduct the gambling expenses incurred in earning the gambling winnings? And can they avoid the withholding tax on their gambling winnings? The court addresses these international tax law issues in Park v. Commissioner, 136 T.C. 569 (T.C. 2011). Facts & Procedural History…

Foreign Branch Income & the Research Tax Credit

The research tax credit is one of the most complicated provisions in our tax code. The international tax law aspects of this credit are even more difficult to follow. In Deere & Company v. Commissioner, 133 T.C. No. 11, the U.S. Tax Court considered whether income from foreign branches must be included in the gross…

U.S. International Tax Withholding & Reporting (Explained)

International tax law is a complex and ever-evolving area of law that governs the taxation of income earned by individuals and businesses across different countries. As globalization continues to increase, cross-border transactions become more prevalent, and more individuals and businesses work across borders, understanding international tax law has become increasingly important. One key area of…

What is a “Foreign Country” for Income Tax Purposes?

United States citizens are subject to tax in the U.S. on their worldwide earnings and income. This includes wages earned for work performed in foreign countries. There are exceptions to this treatment, such as the provisions of tax treaties. The other exception involves the foreign-earned-income exclusion. This exclusion allows individual taxpayers to exclude income earned…