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Since passing a two-month extension just before the Memorial Day recess, we continue to hear tales of stalled negotiations between Senate Democrats and Republicans over how to fund a longer-term bill.

On December 19, 2023, the bilateral income tax treaty between the United States and Chile (formally, the Convention between the Government of the United States of America and the Government...

In this article, we explore how income, sales, and employment are taxed in Indian Country — helping Tribal leaders, advisors, and members make informed decisions that support sovereignty and long-term goals.

On February 8, 2012, the US Department of the Treasury (the "Treasury Department") issued detailed proposed regulations to implement the withholding and reporting rules commonly referred to as the "Foreign Account Tax Compliance Act" or "FATCA."

On March 22, 2010, a panel of the US Court of Appeals for the Ninth Circuit reversed its position on an issue of intense interest to multinational corporations that engage in research and development under cost sharing arrangements with their foreign affiliates.

In <EM>Swallows Holding Ltd. v. Commissioner of Internal Revenue Service</EM>, 126 TC No. 6 (January 26, 2006) the Internal Revenue Service (IRS) attempted to disallow all deductions claimed on certain late filed tax returns by a foreign corporation because the returns were filed after the expiration of the 18-month grace period set forth in Treasury Regulation 1.882-4(a).

The IRS has indicated that it will waive failure to file penalties with respect to delinquent Forms 5471 and similar information returns, in situations where foreign income has been reported and taxes paid, provided such filings are made by September 23, 2009.

Unlike FDAP income, the United States taxes effectively connected income ("ECI") on a net basis.

The Hiring Incentives to Restore Employment Act (the "HIRE Act"), signed into law this past March, includes certain foreign account tax compliance provisions designed to combat offshore tax evasion through increased tax withholding and information reporting obligations with respect to "withholdable payments" made to certain foreign entities (the "FATC Provisions").

The New York State Tax Appeals Tribunal has held that out-of-state corporations that had passive ownership of a partnership conducting business in the state had nexus for purposes of New York corporation franchise tax.

Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm's length principle.

On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive...

The U.S. Senate, in a vote of 95-2 on June 22, 2023, approved a Resolution of Advice and Consent (the Resolution) to ratify the Convention Between the Government of the United States...

Much of the current litigation between taxpayers and the United States has centered on the definition of willfulness or whether the non-willful FBAR penalty should apply...

If you travel frequently to—or are considering moving to—the US, it's essential to understand US tax residency and how to manage tax and reporting obligations effectively to avoid complications.

On June 9, 2009, the IRS issued new final and temporary regulations (T.D. 9453) under the "anti-inversion"; rules of Section 7874 of Internal Revenue Code of 1986, as amended (the "Code").

Nothing is certain in this world, except death and taxes – and even taxes are subject to change.