Tax & Accounting Blog

Regulations Require Updating of Employer Identification Numbers

Regulations Require Updating of Employer Identification Numbers

On May 3, 2013, the IRS issued final regulations that require any person assigned an employer identification number (EIN) to provide updated information to the IRS in the manner and frequency prescribed by forms, instructions, or other appropriate guidance.  These regulations affect persons with EINs and will enhance the IRS’s ability to maintain … Read More

New Canadian Withholding Tax Documentation Requirements

New Canadian Withholding Tax Documentation Requirements

The Canada Revenue Agency (CRA) has changed its procedures for determining whether non-residents can claim a reduced rate of withholding tax under a tax treaty. Background Canada imposes a 25% withholding tax on certain types of Canadian source income paid to nonresidents of Canada.  Residents of countries with which Canada has a treaty may be … Read More

onesource

Thomson Reuters ONESOURCE named Americas Tax Innovator of the Year

Last week, International Tax Review recognized Thomson Reuters ONESOURCE platform as Americas Tax Innovator of the Year at its seventh annual Americas Awards ceremony in New York. When asked why Thomson Reuters ONESOURCE was singled out for the award, Ralph Cunningham, managing editor of International Tax Review, said: “It is down to the impact … Read More

Final Regs Detail Bank Deposit Interest Reporting for Nonresident Aliens

Final Regs Detail Bank Deposit Interest Reporting for Nonresident Aliens

On April 17, 2012, the IRS issued final regs that require information reporting for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals resident in countries with which the U.S. has in effect an information exchange agreement (as listed in Rev. Proc. 2012-24, which has been issued … Read More

Open Transaction Doctrine does not apply in insurance company demutualization case.

Open Transaction Doctrine does not apply in insurance company demutualization case.

On July 9, 2012, a federal district court in Arizona ruled that the taxpayer could not apply the “open transaction” doctrine in a case involving stock received from an insurance company that demutualized. Background. A mutual insurance company has no shareholders.  Instead, the policyholders have an ownership interest in the company, in addition to having … Read More

Estates of Some 2011 Decedents Get More Time to Make Portability Election

Estates of Some 2011 Decedents Get More Time to Make Portability Election

The IRS has issued guidance giving certain estates of married individuals who died during the first six months of 2011 an extension of the deadline to make the portability election to pass the decedent’s unused estate and gift tax exclusion amount to the surviving spouse. Estates qualifying for and taking advantage of the extension will have … Read More