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On September 17, 2009, the Internal Revenue Service (“IRS”) issued Notice 2009-78 (“Notice”) announcing its intention to issue additional regulations under the “anti-inversion” rules of Section 7874 of the Internal Revenue Code of 1986, as amended (“Code”).

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as the "revenge tax."

GE Financial Investments Limited ("GEFI Limited") was a UK incorporated and tax resident company and a member of the General Electric group.

The Senate's attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess.

With all of the payroll complexities that employers face, it is no surprise that a special set of rules that applies to only a small category of employees is frequently overlooked.

Generally, income from the sale of personal property is "sourced" to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed to be the United States.

In the past few weeks, attention has focused on Washington and how the politicians would deal with the tax component of the so-called fiscal cliff (the tax increases that would automatically go into effect on January 1).

The I.R.S. Large Business and International division ("LB&I") recently announced the approval of the following six additional compliance campaigns:

President Obama’s budget proposal provides further restrictions on domestic corporations expatriating through corporate inversion transactions.

In a helpful recent private letter ruling, the Internal Revenue Service illustrated a method allowing multinational corporations seeking tax-efficient ways to repatriate offshore cash to avoid the obstacle posed by Johnson v. United States.

We have previously discussed the significance of March 18, 2012 as the effective date of certain cross-border tax provisions included in the Foreign Account Tax Compliance Act ("FATCA"). FATCA was enacted on March 18, 2010 as part of the Hiring Incentives to Restore Employment Act.

In our previous post published on 6 December 2016 we described the OECD's BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion...

Like many countries, Germany imposes a withholding tax on dividends paid to foreign investors.

The Internal Revenue Service in Ecuador established regulations in regards to indirect expenses in order to apply a deductibility threshold for these expenses when calculating the Income Tax for Ecuadorian taxpayers...

A temporary excise tax recently enacted in Puerto Rico will have a significant impact on U.S.-based multinational groups conducting, or considering conducting, manufacturing activities in the country.

The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) that provides helpful guidance regarding the application of the branch profits tax in connection with reverse foreign hybrid entities and U.S. income tax treaties with foreign countries.

As with the Tax Cuts and Jobs Act (TCJA) in 2017, the 2025 calendar year ushered in a new set of tax legislation – the One Big Beautiful Bill Act (OBBBA)...