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International Tax

International Tax 

This section covers international taxation and reporting issues. It contains articles, tools and practice aids, as well as comment letters pertaining to legislative matters and IRS regulation and administration. Some of the topics in this section include:

Practice Support 

  • Register now!AICPA 2012 International Business Conference, June 10 - 12, Washington, DC.  Tax sessions include workshop Getting Your Arms Around U.S. International Tax Compliance; Withholding Tax Regime of the HIRE Act; Transfer Pricing for Lending and Leasing Transactions; Cross-Border Restructuring Transactions; New U.S. International Tax Developments; and Executive Relocations:  Corporate Planning and Related Tax Strategies.

 

 

 

 

 

 

 

 

 

  • Many calendar 2011 FBARs still due by June 30, 2012.  However, FinCEN Notice 2012-1 extends the due date to June 30, 2013 for 2011 and earlier years for those FBAR filers previously identified in FinCEN Notices 2011-1 (as revised) and 2011-2.

     

    • Released 02.08.2012, Proposed Regulations on Sections 1471 - 1474, enacted as part of FATCA, regarding information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities.  The proposed regulations affect persons making certain U.S.-related payments to FFIs and other foreign entities and payments by FFIs to other persons. Public hearing on 05.15.2012.  Tax Adviser Article summarizing the proposed regulations.  Joint Statement on intergovernmental approach to improving international tax compliance.

     

     

     

    • Offshore Voluntary Disclosure Program reopened 01.09.2012 for indefinite period, for those with undisclosed income from offshore accounts to get current with their U.S. federal income taxes.  More information to be released by IRS in next month.  Indicates procedures being developed for dual citizens.

     

    • Final Regulations on Section 954 regarding foreign base company sales income (FBCSI) - effective for taxable years of CFCs beginning after 06.30.2009, and for taxable years of U.S. shareholders in which or with which such taxable year of the CFCs end.

     

     

     

     

     

     

     

    Access to additional tools and aids.

    Advocacy 

    Reporting Foreign Accounts and Assets – FBAR and Form 8938
    In fall 2011, two of our members sat down to discuss their concerns, the concerns of their clients, and the steps they are taking to address both sets of rules regarding the 2011 reporting of foreign accounts and assets on Form TD F 90-22.1 (FBAR) and new Form 8938.

     

     

     

     

    Final Regs. published 02.24.2011 are applicable to reports required to be filed by 06.30.2011 for calendar 2010, and all subsequent calendar years.

     

    • The AICPA was one of the organizations interviewed by the Government Accountability Office regarding nonresident alien tax compliance.  Many of our concerns and recommendations are included in the April 2010 GAO report.

     

    Access to additional advocacy documents.

    Access information on the AICPA's International Taxation Technical Resource Panel and its task forces.

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    Top 11 Reminders for 2011 FBARs

    Article :  List of top 11 reminders for 2011 FBARs, from AICPA webcast on May 7, 2012 regarding What You Need to Know for 2011 FBARs:  Required reporting of foreign bank and financial accounts due by June 30, 2012.  Form TD F 90-22.1 - Report of Foreign Bank and Financial Accounts.
    Published on May 21, 2012

    Archive of May 7, 2012 AICPA Calendar 2011 FBAR Infocast

    Webcast :  The materials and replay of this event are now available for free without CPE for Tax Section members.  The AICPA held an audio and slide infocast on Monday, May 7, 2012 from 2:00 to 3:30 p.m. Eastern on What You Need to Know for 2011 FBARs:  Required Reporting of Foreign Bank
    Published on May 21, 2012

    May 7, 2012 Calendar 2011 FBAR Infocast Presentation and Supplemental Materials

    Webcast :  The presentation and supplemental materials from the AICPA audio and slide infocast held on Monday, May 7, 2012 from 2:00 to 3:30 p.m. Eastern on What You Kneed to Know for 2011 FBARs:  Required Reporting of Foreign Bank and Financial Accounts Due by June 30, 2012.
    Published on May 21, 2012

    Archive of March 20, 2012 AICPA Form 8938 / IRC Section 6038D Infocast

    Webcast :  The materials and replay of this event are now available for free without CPE for Tax Section members.  The AICPA held an audio and slide infocast on Tuesday, March 20, 2012 from 2:00 to 3:30 p.m. Eastern on IRC Section 6038D:  Specified Foreign Financial Asset Reporting:  When is form 8938 required
    Published on May 21, 2012

    FBAR and FATCA Webcasts / Trainings

    Overview :  This page contains links to various webcasts and training events regarding the reporting of foreign bank and financial accounts (FBAR) on Form TD F 90-22.1, as well as the separate reporting of specified foreign financial assets on Form 8938.
    Published on May 21, 2012

    FBAR and FATCA Resources

    Overview :  Many taxpayers are required annually to report foreign bank and financial accounts to the U.S. government on Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, (often referred to as FBAR) and are required to pay U.S. tax on income of those foreign accounts, as appropriate.  This reporting requirement
    Published on May 21, 2012

    Form TD F 90-22.1 (FBAR) - January 2012 Version

    Form :  Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, version as of January 2012 (current still as of May 7, 2012, date of AICPA infocast on calendar 2011 FBARs).  Filers should also check that they are using the most current version of this form available at the time
    Published on May 21, 2012

    Slides from May 7, 2012 2011 FBAR Infocast

    Webcast :  Slides from the AICPA audio and slide infocast held on Monday, May 7, 2012 from 2:00 to 3:30 p.m. Eastern on What You Need to Know for 2011 FBARs:  Required Reporting of Foreign Bank and Financial Accounts Due by June 30, 2012.
    Published on May 21, 2012

    Speaker Bios from May 7, 2012 2011 FBAR Infocast

    Webcast :  Speaker biographies from the AICPA audio and slide infocast held on Monday, May 7, 2012 from 2:00 to 3:30 p.m. Eastern on What You Need to Know for 2011 FBARs:  Required Reporting of Foreign Bank and Financial Accounts Due by June 30, 2012.
    Published on May 21, 2012

    FBAR and FATCA Articles

    Overview :  This page contains links to various articles regarding the reporting of foreign bank and financial accounts (FBAR).
    Published on May 15, 2012

    AICPA FBAR Tools and Aids

    Tools :  The AICPA has developed various tools and aids that may assist taxpayers and tax practitioners in understanding the rules regarding FBAR and the preparation of the annual FBAR.
    Published on May 15, 2012

    March 20, 2012 Form 8938 / IRC Sec. 6038D Infocast Presentation and Supplemental Materials

    Webcast :  The presentation and supplemental materials from the AICPA audio and slide infocast held on Tuesday, March 20, 2012 from 2:00 to 3:30 p.m. Eastern on IRC Section 6038D:  Specified Foreign Financial Asset Reporting:  When is form 8938 required in 2011 Individual Income Tax Returns?
    Published on May 14, 2012

    Non-OVDI Filings under FAQs 17 & 18 Extended to September 9, 2011 As Well

    Article :  Late on August 29, 2011, the IRS issued a statement extending the due date for certain late filed FBARs and other information returns from August 31, 2011 to September 9, 2011 due to Hurricane Irene.  These information returns are not subject to late filing penalties per frequently asked questions (FAQs) #17
    Published on May 11, 2012

    IRS Form 8938 Preparation and Filing Resources

    Overview :  This page contains links to various documents from the IRS to assist taxpayers and tax practitioners in the annual preparation and filing of Form 8938, Statement of Specified Foreign Financial Assets, as required by IRC section 6038D.
    Published on May 11, 2012

    IRS / FinCEN FBAR Preparation and Filing Resources

    Tools :  Links to various documents from the IRS and the Financial Crimes Enforcement Network (FinCEN) to assist taxpayers and tax practitioners in the annual preparation and filing of FBAR.
    Published on May 11, 2012

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