...

April 22, 2020

Treasury, IRS announce cross-border tax guidance related to travel disruptions arising from the COVID-19 emergency

U.S. Tax Planning /

  IR-2020-77, April 21, 2020 WASHINGTON — The Treasury Department and the Internal Revenue Service today issued guidance that provides relief to individuals and businesses affected by travel disruptions arising from the COVID-19 emergency. The guidance includes the following: 1. Revenue Procedure 2020-20 (PDF), which provides that, under certain circumstances, up to 60 consecutive calendar days […]

Treasury, IRS announce cross-border tax guidance related to travel disruptions arising from the COVID-19 emergency Read More »

Grantor Trust

U.S. Tax Planning /

Generally speaking, an arrangement will be treated as a “trust” (as opposed to some other type of entity) under the Internal Revenue Code (IRC), if it can be shown that the purpose of the arrangement is to vest in trustees responsibility for the protection and conservation of property for beneficiaries who cannot share in the

Grantor Trust Read More »

Subpart F Income from CFC subsidiaries

FATCA / CRS, U.S. Tax Planning /

I have previously discussed subpart F – https://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html https://www.mooresrowland.tax/2020/02/the-tax-cuts-and-jobs-acts-impact-on.html Consider first a fact pattern where a U.S. parent owns CFC1, which sells the stock of CFC2. 1. CFC2 was originally formed by CFC1, which invested $150 in the stock of CFC2. 2. CFC2 has incurred operating losses of $100 and has $50 of remaining basis

Subpart F Income from CFC subsidiaries Read More »