On February 20, 2014, the Internal Revenue Service issued additional final and temporary regulations under the Foreign Account Tax Compliance Act of 2009.

The IRS has introduced a new Automatic Exemption from Penalty program while a federal court struck down key GILTI regulations in a significant post-Loper Bright decision. The Treasury and IRS also finalized guidance on life insurance contract transactions and updated various energy-related tax credits and reporting requirements.

On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey's Corporation Business Tax ("CBT"). The bill enacted a variety of clarifications, corrections, and modifications to the CBT.

On December 22, 2021, the European Commission adopted a draft Directive laying down rules to prevent the misuse of shell entities for tax purposes (COM/2021/565 final)...

On a fully distributed basis, profits of a corporation are taxed twice. First, profits are taxed at the corporate level.

On September 21, 2007, United States Treasury Secretary Henry Paulson and Canadian Finance Minister Jim Flaherty signed the much anticipated 5th protocol to the existing United States-Canada income tax treaty (the "Treaty").

It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign...

US corporate executives relocating abroad face complex tax obligations that extend beyond borders. From worldwide income taxation and foreign tax credits to state residency issues and potential expatriation taxes, understanding these planning areas is essential for avoiding costly penalties and optimizing your tax position.

The Report on Action 15 of the BEPS action plan (the "Report") was released in September 2014. The goal of Action 15 is to streamline and simplify the implementation of the other BEPS-related measures.

Below is the Federal Policy team's weekly preview, posted when Congress is in session

Click here to read more insights on how we can weather the coronavirus outbreak with you.

The US Foreign Account Tax Compliance Act ("FATCA") is an extraordinarily complex piece of legislation that will be extremely burdensome for affected entities in the UK to comply with.

Individuals who wish to make contributions to foreign charities should be aware of the increasingly regulated landscape surrounding international charitable giving and estate planning.

By temporarily liberalizing section 956, the IRS seeks to aid companies facing challenges as a result of illiquidity in the commercial paper and other key credit markets.

Earlier this week, the “Foreign Account Tax Compliance Act of 2009” (the “bill”) was introduced in the Senate and the House.

On August 10, 2010, the President signed into law the Education Jobs and Medicaid Assistance Act of 2010. The new Act is designed to provide nearly $10 billion in healthcare funding.

The anticipated government shutdown was avoided by the surprise bipartisan continuing resolution (CR), the Continuing Appropriations Act, 2024 and Other Extensions Act...

The recent Zhang v. United States case, Docket No. 21-17093 (9th Cir. Oct. 18, 2022), serves as a reminder that the Internal Revenue Service (IRS) can force you to disclose and share your tax...

On May 31, 2016, the Washington Department of Revenue Appeals Division released a Determination denying a German pharmaceutical company's business and occupation tax protest.

On November 2, 2011, the Internal Revenue Service (the "IRS") and the Treasury Department issued proposed Treasury Regulations (the "Proposed Regulations")1 which modify and clarify the temporary Treasury Regulations promulgated in 1988 (the "Temporary Regulations") under Section 892 of the Internal Revenue Code of 1986, as amended (the "Code")