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If There Are Nonresident Partners In A Partnership Tax Return Filing, Is There Anything Special You Are Required To File With The Return?
User Photo Gary Carter, PhD, MT, CPA
Tax Professional Level: Tax Enthusiast

Under IRC Section 1446, a partnership that has income effectively connected with a U.S. trade or business must pay a withholding tax on the effectively connected taxable income that is allocable to its foreign...   Read More
Will The IRS Give Us Any Tax Relief If We Lost Our Entire Household Belongings In Hurricane Sandy?
Tax Professional Level: Tax Enthusiast

The IRS is probably working on tax relief for all the individuals affected by Hurricane Sandy as we speak. I'm sure you will get relief. Please check back as I am sure another tax adviser will provide you...   Read More
Would Some One Explain What Is FATCA? Why Was It Intreduced? What Impact Does It Have On USC Living Abroad?
User Photo Lisa Nason CPA, MST
Tax Professional Level: Tax Enthusiast

FATCA stands for The Foreign Account Tax Compliance Act (FATCA) Under FATCA, U.S. taxpayers with specified foreign financial assets that exceed certain thresholds must report those assets to the IRS. This reporting...   Read More
What Is A Dual Consolidated Loss?
User Photo Douglas Stransky
Tax Professional Level: Tax Enthusiast

In general, Treas. Reg. § 1.1503-2(b)(1) provides that a “dual consolidated loss” of a “dual resident corporation” cannot offset the taxable income of any domestic affiliate in the taxable year in which...   Read More
What Is A Controlled Foreign Corporation?
User Photo Douglas Stransky
Tax Professional Level: Tax Enthusiast

Under Internal Revenue Code section 957(a), a controlled foreign corporation ("CFC") is defined as a foreign corporation in which, on any day of its tax year, greater than 50% of the voting power or value of its...   Read More
What Is Subpart F And Why Was It Created?
User Photo Douglas Stransky
Tax Professional Level: Tax Enthusiast

Subpart F (under Internal Revenue Code sections 951-964) was enacted in 1962 in an effort to avoid improperly encouraging foreign investment by U.S. investors. The provisions provide that U.S. investors in...   Read More
What Protection Do I Get From Tax Treaties? How Do I Access Them If I Need Them?
User Photo Douglas Stransky
Tax Professional Level: Tax Enthusiast

This link to the IRS website provides a high-level overview of the benefits of income tax treaties. It also provides links to the current treaties in force.   Read More


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