IRS Limits Advance Rulings on Foreign Employee Tax Exemptions Many foreign employees working in the United States may qualify for reduced taxes or exemptions under U.S. tax treaties or specific provisions of the Internal Revenue Code. However, the IRS generally limits the availability of advance rulings on many of the questions that determine whether those...

IRS Limits Tax Benefits for Foreign Government Commercial Activities Section 892 of the Internal Revenue Code provides valuable tax benefits for qualifying foreign governments, central banks, and certain government-owned entities. However, these benefits are carefully limited and generally apply only to specific types of passive or governmental investment income. The IRS has consistently distinguished between...

IRS Tightened Foreign Tax Credit Eligibility Rules for International Taxpayers The Foreign Tax Credit (FTC) helps reduce double taxation by allowing U.S. taxpayers to claim a credit for certain income taxes paid to foreign countries. However, recent IRS regulations significantly tightened the standards for determining which foreign taxes qualify for the credit. Although temporary relief...

IRS May Reject Frivolous Tax Arguments and Certain Incomplete Ruling Requests The IRS has procedures in place to prevent taxpayers from delaying tax administration through frivolous arguments or incomplete requests. Depending on the type of IRS proceeding, a submission may be rejected without receiving the full administrative review that taxpayers normally expect. Understanding these rules...