In the blogs: More than a trend

Using AI to teach accounting; CPAs and financial statements; TIGTA on joint returns; and other highlights from our favorite tax bloggers.

More than a trend

New life for taxing overseas?

Virginia – U.S. Tax Talk (https://us-tax.org/about-this-us-tax-blog/): Nearly a year ago, Rep Darin LaHood, R-Illinois, introduced a groundbreaking piece of legislation that sent ripples through the expat community and the international tax world: the Residence-Based Taxation for Americans Abroad Act (H.R. 10468). It represented a bold step toward aligning the U.S. tax system with the rest of the world — and faced an uphill battle right out of the gate. Now, thanks in part to former top IRS officials Charles Rettig and Tom Cullinan, the act may have a better shot.
Tax Vox (https://www.taxpolicycenter.org/taxvox): Post-OBBBA, it’s understood that the U.S. is on an unsustainable fiscal path absent policy changes. The ratio of debt to GDP is projected to rise substantially and inexorably over the next several decades, with no natural turning point. How should U.S. policymakers respond? Maybe look abroad.
Taxnotes (https://www.taxnotes.com/procedurally-taxing): An examination of the Treasury Inspector General for Tax Administration’s annual report on collection activity concerning joint returns, with tips for taxpayers seeking information from the IRS about a spouse’s or ex-spouse’s account information under Sec 6103(e)(8).
Global Taxes (https://www.globaltaxes.com/blog.php): A U.S. court has dismissed a significant FBAR penalty lawsuit, saying that the IRS assessment of such a penalty violates taxpayer rights — potentially providing a new defense for filers of these returns.
Eide Bailly (https://www.eidebailly.com/taxblog): One of the most fundamental and profound questions in transfer pricing is: “What is a related party?” This frequently arises in joint ventures, private equity portfolios and complex group ownership structures, and the answer typically centers on the concept of common control.
National Association of Tax Professionals (https://blog.natptax.com/): The IRS has announced limited penalty relief for remittance transfer providers due to the new 1% excise tax on international money transfers set to take effect Jan. 1 under OBBBA. The new tax marks a significant shift in how money transfer businesses will handle compliance and reporting.
The Tax Times (https://www.thetaxtimes.com) The U.S. Court of Appeals has issued a “pivotal decision” in 3M Company and Subsidiaries v. Commissioner, reversing the U.S. Tax Court’s 2023 ruling in favor of the IRS. The court held that the IRS could not impose U.S. tax on “blocked” royalty income that 3M was legally prohibited from receiving under Brazilian law.
Current Federal Tax Developments (https://www.currentfederaltaxdevelopments.com/): For tax pros dealing with foreign investment in U.S. real property, the Treasury has released proposed regulations under IRC Sec. 897 to withdraw the domestic corporation look-through rule that was adopted in final regs issued last year.