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After nearly two decades of negotiations, Belgium and France signed a new Income Tax Treaty on November 9, 2021 (the "New Treaty"). The New Treaty is in line with the latest O.E.C.D.

Following the lead of the O.E.C.D. and the European Commission ("E.C."), the Tax Cuts and Jobs Act ("T.C.J.A.") adopts several provisions designed to end certain tax planning opportunities.

On April 4, 2016, the Treasury and the IRS released proposed regulations under Code Sec. 3851 addressing whether purported indebtedness issued to certain related parties will be treated as stock...

When asking a U.S. tax adviser to describe the "revenue rule," it would not be surprising for the adviser to say that it refers to formal guidance issued by the I.R.S. that can be relied on by other taxpayers as authority for a position taken in a tax return.

On January 1, 1996, a special regime governing Spanish holding companies came into force.

Before you is the Autumn edition of 2025. This edition features many tax changes resulting from governments, especially in Indonesia, Korea, the Philippines, and Vietnam, raising taxes in order to make ends meet...

This Commentary highlights some of the principal calendar and year-end reporting requirements for employee stock plans that U.S. companies most commonly encounter when offering these programs to their employees in selected jurisdictions worldwide.

On March 18, 2010, President Obama signed into law the HIRE Act, economic stimulus legislation intended, among other things, to spur new job creation in the US economy.

For a number of years, many private equity funds have had the ability under their partnership agreements to create “alternative investment vehicles” (AIVs) to facilitate one or more specific investments.

Many issues that arise during the course of a New York State tax audit have long troubled both taxpayers and the Audit Division: from the taxpayer side, lengthy and delayed audits, voluminous or duplicative Information Document Requests ("IDRs").

We held up Tax Talk this quarter in order to bring you the latest on the Trump administration's tax reform plans.

We can’t think of a better way to end Q1 2014 than by bringing you the year’s first issue of Tax Talk.

If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.