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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.

The Tax Court's decision in Container Corp. v. Comm'r will have a significant impact on U.S. corporations that guarantee loans to foreign subsidiaries.

On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation, which was last updated in 2006.

On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty)...

It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024.

On March 22, 2022, the Internal Revenue Service's Advance Pricing and Mutual Agreement Program released its 2021 Announcement and Report Concerning Advance Pricing Agreements.

In October 2011, the Democratic Republic of Congo (DRC) Senate finally ratified the avoidance of double taxation treaty with Belgium (the "Treaty") that was signed on 23 May 2007 and already ratified by Belgium in January 2009.

Several key business tax breaks are set to expire at year end unless Congress acts. Businesses should be aware of these expiring tax provisions and should consult with their tax advisors to determine whether they should take action necessary to take advantage of these tax breaks and/or to plan for the effects of the expiration of others of which they have taken advantage in the past.

A taxpayer's status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien...

On December 5, 2012, the Internal Revenue Service proposed a revenue procedure that would address the general welfare exclusion from gross income as it applies to tribal government programs.

Many taxpayers are familiar with information document requests where taxpayers are notified that taxing authorities are inquiring into certain transactions based on their receipt of the request.

On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.

On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.

The Trump administration has recently advanced a series of initiatives that significantly expand the scope of U.S. economic protectionism, targeting foreign tax practices perceived as discriminatory against American interests.