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When partnerships include foreign partners, U.S. tax compliance can become complicated. Two essential forms that help partnerships meet their tax obligations are IRS Form 8804 and IRS Form 8805.

On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released an update on its efforts to effect major changes in international tax rules.

Credits and externship credits co-mingled during my time at Ruchelman P.L.L.C. While I sought to gain externship credits and learn about the tax world, I spent a lot of time learning about tax credits...

The US Department of the Treasury issued proposed regulations on April 4, 2016, addressing the characterization of certain instruments as debt or equity for US federal income tax purposes (Proposed Regulations).

A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or business within the United States ("ECI")...

As we have previously reported, the Foreign Account Tax Compliance Act ("FATCA") is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope.

On May 17, 2006, the President signed into law the Tax Increase Prevention and Reconciliation Act of 2005 (the Act). Touted as a $70 billion dollar "tax-cut package", the Act amends the Internal Revenue Code of 1986, as amended (the Code) by, among other things, extending certain temporary tax reductions and also implementing several new substantive provisions. This update provides a summary of some of the most noteworthy provisions of the Act, some of which are noteworthy cross-border developme

Many of our clients are interested in engaging in global philanthropy. These individuals often want to benefit charitable causes outside of the United States while still being able to maintain an income tax deduction ...

On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations1 (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA).

This month finds the arm's length principle continuing to operate among O.E.C.D. Member States and the broader inclusive framework working toward international tax reform of the digitized economy.

On April 22, 2025, the Judicial Committee of the U.K. Privy Council released a pivotal decision in Methanex Trinidad v. Board of Inland Revenue ([2025] UKPC 20).

The Foreign Account Tax Compliance Act ("FATCA"), which was signed into law on March 18, 2010, as part of the Hiring Incentives to Restore Employment Act (the "HIRE Act"), includes a number of revenue raising provisions affecting cross-border transactions.

It is quite a human trait to live in a state of suspended disbelief – when the news is just too bad to absorb, or when the consequences of an action are too much to contemplate.

On May 11, the Obama Administration (the "Administration") issued general explanations of its Fiscal Year 2010 revenue proposals, including a number of international tax reform proposals that could have a dramatic impact on multinational businesses and other taxpayers with foreign investments or activities.

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting was released by the Organisation for Economic Co-operation and Development...

The term "NRA withholding" is not a reference to deductions from a person's paycheck to support the National Rifle Association. Instead, it is a general term that refers to federal tax withholdings...

The Bank Secrecy Act ("B.S.A.") requires U. S. persons with certain financial interests in foreign accounts to file an annual report known as an "F.B.A.R.," which is embodied