CALL US:+1-800-322-7776

We wanted to communicate that the IRS will conduct a webinar on February 9 titled “K2/K3 With a Focus on the Foreign Tax Credit – Individuals.”

 

The Organization for Economic Cooperation and Development has adjusted upwards revenue estimates from its international tax framework.

 

The IRS recently posted a revised draft version of the 2022 Partnership Instructions for Schedule K-2 and K-3 (Form 1065) and a similar revised version of the 2022 S Corporation Instructions for Schedules K-2 and K-3 (Form 1120-S).

 

U.S. Federal Courts reached two important decisions on transfer pricing cases as 2022 came to a close.

 

In April of this year, the IRS released a memorandum announcing a change to IRS policy regarding the economic substance doctrine in audits.

 

Consolidated groups have the option to take the position that their aggregate 951(a)(1)(A) and 951A(a) inclusions are reduced by changing the ownership of stock of a CFC within the group. Specifically, taxpayers are taking the position that a group’s aggregate pro rata share of a lower-tier CFC’s subpart F income or tested income is reduced under section 951(a)(2)(B) by reason of both: 1.) a distribution made by the lower-tier CFC to a member, and 2.) a direct or indirect acquisition of stock of the lower-tier CFC by another member.

 

In reflection of our Global Business Services in 2022, our team and client partnerships continue to grow.

On November 4, the Department of the Treasury and the Internal Revenue Service released the 2022-2023 Priority Guidance Plan. The Priority Guidance Plan is published to highlight what is most important for taxpayers and the tax administration.

The IRS recently posted a revised draft version of the 2022 Partnership Instructions for Schedule K-2 and K-3 (Form 1065) and a similar revised version of the 2022 S Corporation Instructions for Schedules K-2 and K-3 (Form 1120-S).

 

When helping clients get current with filing delinquent returns of prior years, we are always asked the question “How far back do we have to go?”

Greg Lambrecht, CPA, is a Shareholder in the firm’s Global Business Services practice and advises clients on international tax matters including understanding the consequences and opportunities associated with global tax planning decisions. He also assists clients in managing increasingly complex compliance requirements of companies with international operations.

Lambrecht joins McGuire Sponsel from the Big Four with over a decade of experience leading complex international tax projects for Fortune 150 clients and over 20 years of total experience in international tax.

Recent Resources