The U.S. Treasury Department released two model agreements that reflect the intergovernmental approach outlined in Treasury's February joint statement with France, Germany, Italy, Spain, and the United Kingdom.

There's little doubt that President Trump will carry through on the many promises that he made during the campaign that affect individuals, investors and advisors in the Wealth Management Industry.

In its recent Formal Opinion 491, issued April 29, 2020, the American Bar Association (ABA) has arguably expanded the obligations of lawyers when they have reason to believe that their clients...

Chicago's Department of Finance currently is offering an amnesty program called the Debt Relief Program (Program).

In Through the Looking-Glass, by Lewis Carroll, Humpty Dumpty makes the following point when speaking to Alice

Brexit—the formal departure of the United Kingdom (the UK) from the European Union (the EU), pursuant to the referendum held in the UK in June 2016—is imminent: the UK will cease to be a member of the EU on March 29, 2019.

We last updated our readers in February 2014 on issues related to the disclosure and automatic exchange of financial information on an international basis.

Employers preparing for year-end compliance efforts should be aware of a December 31, 2012 deadline for correcting a common problem in compensation arrangements subject to Section 409A of the Internal Revenue Code.

The newly introduced Tax Cuts and Jobs Act is a comprehensive tax reform package that touches virtually every area of the tax law.

Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions.

In April, the IRS released a practice unit on country-by-country (or "CbC") reporting. The purpose of the document is twofold: (i) describe the background of CbC reporting...

The IRS has finalized new Section 987 regulations that fundamentally change how businesses with foreign operations report currency gains and losses, with compliance beginning for the 2025 tax year. These regulations require taxpayers to calculate cumulative foreign currency positions dating back to 2006 or entity inception, while IRS Notice 2026-17 offers a simplified election that may reduce administrative burden for qualifying businesses. Understanding these changes now is critical to avoid penalties, ens

The proposed regulations identify 24 types of issues that will not trigger Appeals rights.

The nexus rules are designed to protect the interests of smaller jurisdictions, and in particular developing economies, and their desire to benefit from the new taxing right.

The international business community has witnessed an increase in US tax enforcement activity arising from individual whistleblower claims filed with the US Internal Revenue Service.

Due to the success of the Internal Revenue Service's (IRS) previous voluntary-disclosure program for undisclosed foreign accounts that resulted in 14,700 submissions by the end-date of October 15, 2009, and another 3,000 submissions after that date, on February 8, 2011, the IRS announced a second initiative for the disclosure of unreported foreign accounts in exchange for reduced penalties.

There is increasing uncertainty about the future of U.S. estate tax. On the one hand, under U.S. legislation that temporarily halved the lifetime exemption amount passed...

With the objective of enhancing transparency and public scrutiny on corporate income tax, the European Commission adopted a proposal.

On 18 February, 2020, the Council of the European Union (the "EU Council") added the Cayman Islands to the EU's official list of non-cooperative jurisdictions, ...

Most employment lawyers are at least somewhat familiar with the US tax rules on deferred compensation under Section 409A of the US Internal Revenue Code.