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")

There have been several cases in Europe and beyond over the past few years concerning the concept of beneficial ownership under double tax agreements ("DTAs").

United States citizens and ‘greencard holders’ who live outside the United States must still report and pay US tax on their worldwide income.

On May 30th, the IRS issued Revenue Procedure 2020-20 which provides non-U.S. individuals present in the U.S. some limited relief from the day-count tests for U.S. tax residency and...

The Kentucky Board of Tax Appeals (the "KBTA") recently held Netflix's streaming service does not qualify as "multichannel video programming service" ("MVPS") and is not subject to the gross revenues tax and excise tax on MVPS, imposed pursuant to KRS § 136.616 and KRS § 136.604, respectively

Several recent rulings concerning the tax exemption applicable to institutional investors into Italian real estate investment funds ("*REIFs*")

Many Alabamians are struggling to cope with the devastating effects of the recent storms and flooding.

Four years after the OECD and G20 countries adopted a 15-point action plan to attack base erosion and profit shifting (BEPS), a new era of international taxation was launched on June 7 when 68 countries signed a multilateral instrument.

The US Internal Revenue Service has revised the applicability dates for proposed regulations under Section 892 affecting foreign government investments in the United States, providing crucial clarity on when new...

On February 1, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2011 Revenue Proposals (2011 Green Book), which includes the Obama administration’s plans to significantly reform the U.S. international tax system.

The United States and Brazil have signed a "Model 1" intergovernmental agreement ("IGA") with respect to the US Foreign Account Tax Compliance Act.

The US Treasury and IRS have issued new proposed regulations modifying the applicability dates for Section 892 rules affecting foreign government investors, providing crucial transitional relief and grandfathering protection...

As increasing transparency and concern over reputational issues cause a drop in the popularity of offshore structures, onshore structures are becoming more attractively competitive.

Article 13B(d)6 of the EU Sixth VAT Directive 77/388/EEC (the Sixth VAT Directive) provides that fees arising from the management of special investment funds (as defined by Member States) are exempt from VAT.

On July 1, 2014, FATCA will go into effect.

On August 7, 2009, the Internal Revenue Service (the “Service”) issued Notice 2009-62, which extends the deadline for filing Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts, or “FBAR”) from September 23, 2009 to June 30, 2010 for two groups of U.S. persons for 2008 and prior calendar years.

On April 2, 2014, the U.S. Internal Revenue Service issued Announcement 2014-17, which provides certain FATCA relief.

On May 17, 2006, President Bush signed into law H.R. 4297, the “Tax Increase Prevention and Reconciliation Act,” (the “Act”), a $70 billion tax package that will extend the reduced individual 15 percent tax rate on certain dividends and long-term capital gains from the end of 2008 through December 31, 2010. The Act increases the alternative minimum tax exemption levels for 2006 and extends provisions permitting small businesses to expense up to $100,000 in investments in depreciable assets for

In late August, Hurricane/Tropical Storm Irene ripped through much of the East Coast leaving a wake of storm and flood damage.