525 results found

U.S. domiciliaries are generally subject to U.S. Federal estate tax, gift tax and generation-skipping transfer tax (the "GST tax") in the same manner as U.S. citizens

On March 18, 2010, the Foreign Account Tax Compliance Act ("FATCA"), Subtitle A of Title V of Public Law 111-147, was enacted into law.

The reliance on smartphone G.P.S. applications is nearly ubiquitous in today's world. These "map apps" not only furnish diverse routes to destinations...

Many fund managers establish investment funds in offshore "tax haven" jurisdictions to satisfy the tax efficiency requirements of their tax-exempt investors (i.e., non-profit entities such as foundations and pension funds).

This bulletin summarizes the landmark legislation – House Bill 427 – that was introduced last Thursday by Representative Paul DeMarco, and will be handled in the Senate by Ben Brooks of Mobile (SB 347), which reflects the work of members of the Alabama State Bar Tax Section, in cooperation with the Alabama Department of Revenue ("ADOR") and members of the Alabama Society of CPAs ("ASCPA"), over the past several years.

For starters, the test operates not on a single-year basis but on a rolling basis under which days are weighted in order to arrive at the 183 day total.

Not all is exciting when a foreign student gets a job offer from a U.S. employer under the Summer Work Travel Program administered by the U.S. Department of State

Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.

In its 2019 Spring Term, the Supreme Court published five decisions regarding tax matters, three of which limit states' taxing authority.

A key initial decision for a manager launching a new hedge fund is to decide between...

On February 1, 2023, the OECD Forum on Tax Administration published its Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements.

With the release yesterday by the House Ways & Means Committee of draft statutory text of the Tax Cuts and Jobs Act, and with GOP majorities in both chambers of Congress proceeding...

Investor appetite for direct lending has remained consistently strong in recent years.

The divergence between US and European approaches to Pillar Two raises a question for US multinationals that have traditionally located holding companies...

Continuing its implementation of the Foreign Account Tax Compliance Act, the US Treasury Department recently released a package of proposed and temporary regulations.

The common law revenue rule is a judicial doctrine that prevents courts in one country from being used by a foreign government as a tool to collect lost tax revenue of any kind. As explained by one...

The COVID-19 pandemic has resulted in financial losses for many businesses, including manufacturers.

Given the pandemic and all that has come along with it, telecommuting has become the new norm. Employers are increasingly faced with difficult legal issues ...