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U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA).

Global families investing in U.S. real estate face critical tax structuring decisions at acquisition that can either preserve wealth or create decades of avoidable exposure. How should international investors structure their U.S. property purchases to minimize estate tax, FIRPTA obligations, and state tax compliance issues before closing the deal?

The U.S. applies a worldwide tax system imposed on residents and citizens alike.

On October 7, 2020, the U.S. Internal Revenue Service and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests by non-U.S. persons.

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations...

Last year, the Treasury Department proposed new reporting requirements for domestic disregarded entities with one foreign owner.

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations:

On June 5, 2021, the Finance Ministers and Central Bank Governors of the G7 countries issued a Communiqué announcing their agreement on the conceptual framework for a substantial revision...

On November 2, Kevin Brady (R-TX), Chairman of the US House of Representatives' Ways and Means Committee, released the Tax Cuts and Jobs Act, a comprehensive tax reform proposal...

The Education Jobs and Medicaid Assistance Act of 2010 (Pub. L. No. 111-226) (the "Act") became law on August 10, 2010. While the Act’s primary purpose is to provide financial assistance to US states for education and Medicaid spending, several international tax provisions were included to offset the spending increases.

Reconciliation Revival? Ever since Sen. Joe Manchin (D-WV) publicly renounced his support of the House-passed Build Back Better Act (BBBA)

While the U.S. still refuses to sign onto the O.E.C.D.'s Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the "CbC M.C.A.A."), the I.R.S. is making progress...

Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").

Under the proposed Defending American Jobs and Investment Act, introduced in the House of Representatives and approved by the House Ways and Means Committee on May 14, 2025, as part of the Trump administration's tax package known as "The One, Big, Beautiful Bill."

The IRS has outlined plans to revise its Criminal Voluntary Disclosure Program (CVDP) in early 2026, with proposed rules aimed at improving consistency and predictability in handling willful tax noncompliance disclosures.

The overall tenor of the proposed regulations is economic flexibility, and to that end, the proposed regulations are helpful to investors.