What changed for FIRPTA in 2026 for foreign investors in U.S. real estate? Two Treasury releases moved the ground under cross-border deals — the 2025 proposed regulations on domestically controlled REITs repeal the lookthrough rule for U.S. corporate shareholders, and the 2025 final FIRPTA-adjacent Sec. 892 regulations give foreign governments a workable path to hold…
Can the IRS assess a Form 3520 penalty without going to court? Yes. In Zhang v. IRS (N.D. Cal., May 4, 2026), the court held that Internal Revenue Code section 6039F gives the IRS direct assessment authority for a late Form 3520, meaning the form 3520 penalty lands on your account first and you must…
Which global tax changes in 2026 affect my U.S. business? If you have a foreign parent, a foreign subsidiary or cross-border intragroup payments, four do: proposed U.S. foreign tax credit rules with a September 17 comment deadline, Pillar Two registration deadlines arriving jurisdiction by jurisdiction, spreading e-invoicing mandates, and sharply increased transfer pricing scrutiny. International…
What is the Coca-Cola transfer pricing case, and why should other US companies care? The Coca-Cola transfer pricing case is a dispute over how a US parent must price transactions with its foreign affiliates under IRC §482. The Tax Court sided with the IRS in 2020 and the appeal is now before the Eleventh Circuit…
How do foreign entities e-file 1042-S and 1099 forms after FIRE is retired? Through the new IRS Foreign Filer TCC Registration System. It gives foreign filers whose authorized users have no U.S. SSN or ITIN a way to obtain a Transmitter Control Code and transmit information returns electronically through IDES. The way U.S. information returns…
What were the key international tax developments in early-to-mid June 2026? The OECD pushed forward on the global minimum tax (Pillar Two) — releasing practical fixes to the GloBE Information Return (GIR) XML schema for first filings, an updated 2026 consolidated commentary, and new transfer-pricing guidance on intragroup services. In the EU, the Court of…
How is income from the 2026 FIFA World Cup taxed across the U.S., Canada, and Mexico? The 2026 FIFA World Cup is co-hosted by three countries, which raises a thorny question: when a national team earns prize money and other compensation, how is that income sourced among the United States, Canada, and Mexico? To avoid…
What is the foreign earned income exclusion relief under Rev. Proc. 2026-16? The IRS waives the section 911 residency and presence tests for 2025 for qualified individuals who had to leave seven specified countries due to war, civil unrest, or similar adverse conditions. If you’re a US citizen or resident who was living abroad and…
