IRS Tightens Section 892 Rules for Foreign Government Investments Foreign governments investing in the United States have long relied on IRC Section 892, which provides a federal income tax exemption for certain U.S.-source investment income. However, determining whether an entity qualifies for that exemption has become increasingly complex. Recent IRS guidance reinforces that Section 892...
Which Deduction Saves You More in 2026? One of the biggest questions taxpayers face each year is whether to claim the standard deduction or itemize deductions. For the 2026 tax year, the answer is simple: the deduction that saves you more is the one that produces the larger reduction in your taxable income. In...
IRS Tightens Reasonable Cause Reviews: What Taxpayers Should Know in 2026 If you’ve ever requested IRS penalty relief, you’ve likely heard the term “reasonable cause.” While the legal standard hasn’t changed, the IRS appears to be applying it more narrowly in certain situations—particularly for international tax filings and information return penalties. Understanding how the IRS...
Selling Real Estate in 2026? Here’s What You Need to Know About the Tax Rules Selling real estate can have significant tax consequences, but the rules vary depending on the type of property you sell. Whether you’re selling your primary residence, a rental property, an investment property, or a property used for business, the...
IRS Rejects Comfort Rulings Without a Genuine Legal Need Businesses often seek IRS guidance before completing complex transactions. However, under the IRS’s 2026 ruling procedures, requests that simply ask the IRS to confirm an obvious tax result—commonly called “comfort rulings”—are generally discouraged. Instead, the IRS wants ruling requests to involve a genuine legal question that...
IRS Limits Advance Rulings on U.S. Trade or Business Status For foreign individuals and businesses, one of the most important U.S. tax questions is whether their activities create a U.S. trade or business (USTB). The answer can determine whether income is subject to U.S. taxation and filing requirements. However, obtaining an advance IRS determination isn’t...
IRS Clarifies Portfolio Interest Rules for Foreign Investors The portfolio interest exemption can allow certain foreign investors to receive U.S.-source interest without the standard 30% withholding tax. However, qualifying for this exemption requires careful analysis, and recent IRS guidance reinforces that these determinations are based on detailed ownership rules rather than broad assumptions. What...
IRS Rejects Frivolous Tax Arguments—and They Can Be Costly Not every tax position deserves IRS consideration. The IRS continues to take a firm stance against frivolous tax arguments and may impose significant penalties on taxpayers who raise them in tax returns or certain IRS submissions. Before relying on an unconventional tax strategy, it’s important to...
Standard vs. Itemized Deduction in 2026: Which Saves You More? One of the biggest decisions taxpayers make when preparing a federal tax return is whether to claim the standard deduction or itemize deductions. For most taxpayers in 2026, the best choice is simple: claim whichever deduction results in the lowest taxable income. However, recent...
IRS Treats Permanent Establishment Determinations as Highly Fact-Specific For foreign businesses operating in the United States, one of the most important tax questions is whether their activities create a Permanent Establishment (PE) under an applicable income tax treaty. The answer determines whether the United States can generally tax the business’s profits. While the IRS provides...
Copyright by Accu-Tax, Inc. All Rights Reserved.
Copyright by Accu-Tax, Inc. All Rights Reserved.
