Tax Information For International Businesses | |
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Foreign Account Tax Compliance Act (FATCA) FATCA will increase information reporting by foreign financial institutions, non-financial foreign entities, and certain U.S. persons holding financial assets outside the United States. The International Tax Gap Find resources on this page pertaining to the international tax gap — the difference between the amount of tax that taxpayers should pay and the amount that is paid voluntarily and on time. The tax gap can also be thought of as the sum of non-compliance with the tax law. Foreign Athletes and Entertainers A cross-functional Issue Management Team has a three pronged approach directed towards foreign athletes and entertainers. News and Events This section provides the latest news on international taxes. Classification for U.S. Tax Purposes This section will help you determine if you are a "Foreign Person" or a "United States person" for U.S. Tax purposes Essential Concepts of International Taxation The income sourcing rules determine which income is taxable to a foreign person and which income qualifies for the foreign tax credit and the earned income exclusion of US persons. Competent Authority Assistance If you are a U.S. citizen or resident, you can request assistance from the U.S. competent authority if you think that the actions of the United States, a treaty country, or both, cause or will cause a tax situation not intended by the treaty between the two countries. Competent Authority Agreements A Competent Authority Agreement is a bilateral agreement between the United States and the treaty partner to clarify or interpret treaty provisions. Tax Treaties Tax treaties may allow residents of foreign countries to be taxed at a reduced rate, or be exempt from U.S. income taxes on certain items of income they receive from sources within the United States. Taxpayer Identification Numbers (TIN) A Taxpayer Identification Number (TIN) is an identification number used by the Internal Revenue Service (IRS) in the administration of tax laws. Tax Withholding This section covers tax withholding topics for U.S. citizens or resident aliens employed in U.S. provinces or overseas. Transfer Pricing Provides information about initiatives relative to the issue of transfer pricing. Advance Pricing Agreement Program The APA Program provides an alternative dispute resolution mechanism for taxpayers and the IRS to resolve complex international transfer pricing cases. Qualified Intermediaries (QI) A Qualified Intermediary (QI) is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified intermediary withholding agreement with the IRS. A QI is entitled to certain simplified withholding and reporting rules. U.S. Withholding Agent Program Focus enforcing compliance through examinations and voluntary compliance of withholding tax on foreign payments. Responsibilities include coordinating exams and training exam teams, consulting with internal/externals stakeholders, and providing guidance to ensure consistent treatment for taxpayers. List of Approved KYC Rules Provides a list of countries that have submitted KYC rules and links to Country Specific Attachments. International IRS Offices International IRS Office locations and contact numbers. SOI Tax Stats - International Business Tax Statistics Find statistics for both inbound and outbound international corporate activities here. There's also information on specialized areas covering foreign trusts, international boycotts, and more. Income from Abroad is Taxable There have been recent reports about the interest of the Internal Revenue Service (IRS) in taxpayers with bank accounts in Liechtenstein. The IRS' interest, however, extends beyond bank accounts in Liechtenstein to financial accounts anywhere in the world. The IRS reminds you to report your worldwide income on your U.S. tax return and lists the possible consequences of hiding income overseas. Help for Foreign Athletes and Entertainers The Internal Revenue Service (IRS) recently released Form 13930, Application for Central Withholding Agreement (CWA). Forms 5471 - Automatic Assessment of Penalties under IRC Section 6038(b)(1) Beginning January 1, 2009, the Internal Revenue Service Center will automatically assert appropriate penalties on late filed Forms 1120 with Forms 5471 attached. Taxpayers are encouraged to submit delinquent Forms 5471 prior to January 1, 2009. Mandatory Tax Treaty Arbitration The competent authorities of the U.S. and Germany recently signed an arrangement to provide guidance for operating the arbitration procedure that went into force on December 28, 2007. Additionally, the competent authorities prepared guidelines for operating the three-person arbitration boards. Joint International Tax Shelter Information Centre The Joint International Tax Shelter Information Centre (JITSIC) was created in 2004 by the IRS and the tax agencies of the United Kingdom, Canada, and Australia. In 2007, the Japanese National Tax Agency joined JITSIC. In 2009, the member countries identified initial focus areas for JITSIC in the Terms of Reference. Earlier, the countries had signed a Memorandum of Understanding. Exemption from Section 4371 Excise Tax A list of foreign insurers/reinsurers with closing agreements establishing a treaty-based exemption from the section 4371 excise tax on insurance premiums. IC-DISC Audit Guide This IC-DISC Audit Guide is intended to provide guidance to examiners who are auditing a Form 1120 IC-DISC and/or its related shareholder(s). |
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Page Last Reviewed or Updated: March 07, 2012