AICPA Comments to IRS on IFRS and Form 5471 and Related Regulations
October 10, 2008. These are AICPA comments to IRS on IFRS and Form 5471 and related regulations. Learn More>>

AICPA Update on IRS Letter (Sample) Regarding Automatic Assessment of Form 5471 and Form 1120 Penalties Starting January 1, 2009
This is an AICPA update on the IRS Letter Regarding Automatic Assessment of Form 5471 and Form 1120 Penalties Starting January 1, 2009. Learn More>>

Registration Form for AICPA-ABA Teleconference on FBAR/Voluntary Disclosure Program - August 20, 2009

This is a registration form for the AICPA-ABA Teleconference on FBAR/Voluntary Disclosure Program - August 20, 2009. Learn More>>

Unofficial List of Possible Questions from IRS Voluntary Compliance Program

This is a compilation of unofficial questions that may be asked of somene participating in the IRS offshore voluntary compliance initiative in 2009. Learn More>>

IRS Updated FAQs on Voluntary Disclosure (6/24/09) and Report of Foreign Bank and Financial Accounts (FBAR)

This is an updated (6/24/09) IRS FAQs on the IRS Voluntary Disclosure Program and the Report of Foreign Bank and Financial accounts (FBAR) reporting. Learn More>>

AICPA Update on New FBAR Form, Reporting, and Due Diligence Requirements

This is an AICPA update on New FBAR Form, Reporting, and Due Diligence Requirements. Learn More>>

IRS Resources on FBAR and Offshore Income
This is a listing of IRS resources and links on Report of Foreign Bank and Financial Accounts (FBAR) Reporting and Offshore Income. Learn More>>

Highlights of the 2009 IRS Offshore Voluntary Compliance Program

This is an article/guide on the IRS Offshore Voluntary Compliance initiative in 2009. Learn More>>

IRS March 2009 Statements on Voluntary Compliance (Penalty Framework) for Unreported Offshore Accounts, Entities, and Income
This is a March 2009 IRS LMSB Memo and Commissioner Statement on Penalty Framework/Voluntary Compliance for Offshore Accounts, Entities, and Income. Learn More>>

AICPA Comments on Foreign Gift Threshold and Foreign Trust Issues

On March 3, 2008, the AICPA offered comments on the foreign gift threshold and followed up on the IRS response to January 2007 AICPA comments on foreign trust issues. Learn More>>

AICPA Comments on Proposed FTC Regs on Determining Amount of Taxes Paid
On December 18, 2007, the AICPA commented on proposed section 901 foreign tax credit regulations regarding the determination of the amount of taxes paid. Learn More>>

AICPA Comments on Proposed Section 987 Foreign Currency Transaction Regs These March 29, 2007, AICPA comments to IRS discuss various suggestions regarding the 2006 proposed regulations on section 987 foreign currency transactions. Learn More>>   AICPA Comments on CFC Look-Through Guidance December 11, 2006. These comments offer the AICPA's practitioner and taxpayer guidance suggestions regarding the new Controlled Foreign Corporation (CFC) look-through provision of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). Given the short-lived nature of this provision, guidance is needed to enable taxpayers to determine whether and how the provision applies and to assure that the statute's requirements are met. Learn More>>   AICPA Comments on Notice 2005-74 on the Effect of Exchanges on Gain Recognition Agreements February 21, 2006. The AICPA recommends that a successor transferor in an asset reorganization be permitted to assume the obligations associated with an original GRA for the remaining term of that GRA without triggering gain recognition. Learn More>>

Alert on Expat Transitional Rules for New Form 8854 June 15, 2005. This alert covers the new expatriate transitional rules for new form 8854, Initial and Annual Expatriation Information Statement. IRS recent guidance in IR-2005-49 and Notice 2005-36 explains the revised Form 8854 filing requirements which include the American Jobs Creation Act of 2004 (AJCA) tax and reporting changes for individuals who lost their U.S. citizenship or long-term resident status after June 3, 2004. Learn More>>

IRS Audit Checklist for Cost Sharing Arrangements This audit checklist was created by the IRS Large and Midsize Business Division to help international examiners and field specialists, review and evaluate cost-sharing arrangements under Internal Revenue Code reg. section 1.482-7. Learn More>>

IRS Releases Appeals ISP Settlement Guidelines for Latin American Maquiladora Industry April 8, 2005. The IRS has released appeals industry specialization program (ISP) settlement guidelines for the maquiladora industry that address a U.S. entity's depreciation deduction under section 168(g) for tangible property transferred to a maquiladora located in Latin America. Learn More>>

AICPA Comments on Foreign Currency Transaction Regulations August 20, 2003. These comments to the IRS focus on revisions of proposed Section 987 regulations, regarding Notice 2000-20. The comments do not address the section 987 consequences of partnerships, estates, or trusts. Learn More>>

AICPA Recommends Simplifying Foreign Tax Credit Reporting for Mutual Funds February 26, 2003. These comments to IRS provide a proposal to amend Reg. Sections 1.853-2, 1.853-3 and 1.853-4 and modify Form 1116, regarding separate country reporting of foreign tax credit by mutual funds. Learn More>>

IRS Changes Reporting Requirements for Canadian RRSPs and RRIFs At the urging of the AICPA and other groups, the IRS issued Notice 2003-75, which created a simplified reporting regime for U.S. citizens and resident aliens holding interests in Canadian registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs), and the custodians of these accounts. Learn More>>

IRS Responds to AICPA Concerns for Filing the Form 3520 for Canadian RRSPs June 17, 2003. This AICPA alert covers the August 1, 2003, IRS Notice 2003-57 on Canadian RRSPs and Forms 3520 and 3520-A reporting requirements. In response to AICPA and other concerns expressed, the IRS released 14 days before the deadline Notice 2003-57, waiving the filing requirements for Forms 3520 and 3520-A for Canadian RRSP holders who meet certain requirements. Learn More>>

AICPA Comments on the Foreign Trust Reporting Rules for Forms 3520 and 3520-A June 17, 2003. These comments to the IRS focus on the problems for foreign trusts with reporting on Form 3520 and Form 3520-A for Canadian RRSPs. Learn More>>

AICPA Survey Recommends Treaty Negotiation Priorities December 16, 2002. This letter to the Department of the Treasury provides suggestions for future treaty negotiations and possible renegotiation priorities. Learn More>>