Yesterday the U.S. Department of Treasury and the Internal Revenue Service announced that, as a result of the holding in U.S. v. Windsor that Section 3 of the Defense of Marriage Act is unconstitutional, the determination of whether a same-sex couple is legally married for federal tax purposes will be based on the "place of celebration" and not the couple’s place of residence.

In October 2015, the Organization for Economic Cooperation and Development (OECD) finalized its report titled Action 14: Making Dispute Resolution Mechanisms More Effective.

Proposed Section 899, introduced as part of the "Defending American Jobs and Investment Act" (H.R. 591) and incorporated into the House Ways...

The U.S. District Court for the District of Columbia on Sept. 18 rejected the government's claim that federal courts do not have judicial oversight regarding the U.S. competent authority's (USCA's)...

Action 6 (Treaty Abuse) is a key element of the OECD's BEPS Project. Action 6 targets, in summary, "treaty shopping".

COVID-19 has sparked a seismic change in the workplace as many companies have found that working from home ("WFH") has not diminished employee productivity and that employees prefer its...

On October 8, 2019, the Treasury Department and IRS issued proposed regulations confirming that transitions from LIBOR and other interbank offered rates (IBORs)

In an era where global economic dynamics are increasingly influenced by regulatory changes, a significant development has emerged from the Internal Revenue Service (IRS) that promises to redefine the landscape for international partnerships.

Please join us for our webcast Cross-border mergers & acquisitions update for a discussion on recent guidance issued by the IRS and Treasury Department in the cross-border mergers and acquisitions (M&A) area.Joe Calianno, Grant Thornton’s International Technical Tax practice leader, will be joined by Brenda Zent, international tax specialist in the U.S. Department of the Treasury’s Office of International Tax Counsel, as presenters for this event.

As a follow up to its release of a final version of IRS Form 8938 and instructions on February 29, 2012, the IRS released Basic Questions and Answers on Form 8938 (the "FAQs").

Accrual-basis employers sometimes retain the discretion not to pay certain bonuses to employees based on performance in one taxable year until early in the next taxable year.

The New Jersey Division of Taxation (the "Division") has released long-awaited guidance concerning the recent statutory amendments to the Corporation Business Tax ("CBT").

The Pennsylvania Department of Revenue (DOR) recently revised Corporation Tax Bulletin 2019-03, limiting its application to tax years beginning before January 1, 2025. The change creates uncertainty for corporate taxpayers that previously relied on Pennsylvania’s federal consolidated-group approach to avoid a separate state-specific Section 163(j) limitation.

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 ("2010 Tax Relief Act"), signed into law on December 17, 2010, provides individual and business tax relief that includes a two-year extension of capital gains and dividend income rate reductions, a two-year extension of individual income tax rate reductions and certain other individual and business tax relief.

Bipartisan legislation aims to reduce compliance burdens on U.S. citizens living abroad by streamlining overlapping international financial reporting requirements and simplifying tax obligations.

A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. Payments of U.S.-source "fixed and determinable annual or periodic...

Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere.

Stock options are increasingly a significant component of an international executive’s compensation package. A few of the key questions that should be considered follow.

Living abroad can be a wonderful opportunity for many U.S. Persons[1], but a few commonly misunderstood aspects of the U.S. tax system directly impact such "expats," ...

On October 27, 2009, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax writing committees, introduced the Foreign Account Tax Compliance Act of 2009 (the “Bill”) in the U.S. Congress.