The 2017 Tax Cuts and Jobs Act (TCJA) brought significant changes to the U.S. tax code, including the introduction of a new deduction called the Foreign-Derived Intangible Income (FDII) deduction. The aim of this deduction is to incentivize U.S. C corporations to promote exports and service foreign markets.

For taxpayers living and working abroad, it can be quite complicated trying to determine how to file taxes in not one but two tax jurisdictions. The penalties for failing to comply in the U.S. are astronomical. But the clock is ticking on ticking on getting into compliance. Not only does the IRS have additional funding and has recently hired 4,000 more agents but we have a new IRS commissioner. What does that mean for the existing amnesty programs for taxpayers who have either failed to report some of their foreign income or foreign assets? The clock is ticking…

On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (“IRA”), designed to reduce inflation and provide investments in clean energy. The bill has several key provisions, one of which is a new 15% corporate minimum tax on large corporations.