525 results found

A robust and extensive income tax treaty network has worked to the advantage of U.S. corporations and individuals.

On July 23, 2020, the U.S. Department of Treasury ("Treasury") and the Internal Revenue Service (IRS) finalized regulations (T.D. 9902) with respect to the global intangible low-taxed income...

Navigating the complex landscape of US federal income tax rules is crucial for investors and sponsors in private equity, venture capital, and hedge funds. Understanding how different investor categories—from US taxable entities to foreign pension funds—face distinct tax sensitivities can significantly impact investment returns and structural decisions when forming or investing in funds.

On January 31, 2020, the OECD reported significant steps in advancing Pillar One, its approach for the taxation of the digital economy.

The application of the foreign tax credit to the net investment income tax ("N.I.I.T.") has been a recurring battle in courtrooms in recent years. In the most recent installment...

On December 5, 2024, the United States Court of Federal Claims (the 'Claims Court') issued a partial summary judgment decision in the case of Bruyea v. United States, No. 23-766T (Dec. 5, 2024).

The first step in advising a foreign individual who is neither a U.S. citizen nor a green card holder on U.S. income tax laws is to determine the person's residence ...

On May 22, 2025, the US House of Representatives passed a bill that includes tax increases on certain foreign persons to target purported unfair taxes imposed by foreign countries.

On February 27, 2008, the Treasury Department (Treasury) and the Internal Revenue Service (the Service) released proposed regulations that provide comprehensive guidance on the treatment of contract manufacturing arrangements under the foreign base company sales income (FBCSI) rules of subpart F.

The Johannesburg Tax Court reached a similar conclusion, albeit along a different path, in a case that addressed a matter involving a U.S. service provider.

Whether a business is looking to reduce its tax exposure or an individual is looking for some piece of mind, state and local tax amnesty programs can be a real opportunity for some taxpayers.

The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation...

Despite all the geopolitical issues swirling around the United States (or perhaps because of them), our law firm has never been busier helping foreign companies establish a business here.

Using deductible interest payments to reduce U.S. taxable income is often a goal of tax practitioners.

In a general legal advice memorandum dated September 8, 2025, with a release date of September 19 (the "GLAM"), the Chief Counsel's office...

With the unfortunate emergence and rapid spread of the coronavirus (COVID-19) pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States