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  • Article

    The Tax Cuts And Jobs Act

    Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the "Tax Cuts and Jobs Act".
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    Certainty By Design: A Practical Guide To Prefiling Agreements, Closing Agreements, Private Letter Rulings, And Tax Opinions

    Tax executives face material transactions that cannot wait for litigation to resolve interpretive uncertainty. This practical guide explores four critical IRS mechanisms—prefiling agreements, closing agreements, private letter rulings, and tax opinions—that provide varying levels of certainty for managing tax exposure before issues reach examination. Through conversations between controversy and transactional practitioners, discover when and how to deploy these tools along the continuum from inf
    United StatesTax
Dinsmore & Shohl LLP
Dinsmore & Shohl LLP
  • Article

    The Revenue Rule And The Recognition Of Tax Claims In Cross-Border Cases

    In the nearly seven years since the United States Bankruptcy Code was amended to include a new Chapter 15 to address cross-border insolvencies.
    United StatesTax
    Archer & Greiner P.C.
    Archer & Greiner P.C.
  • Article

    The Final State Of Expatriation?

    Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 (“HEART” or the “Act”)1 dramatically alters the playing field for individuals who relinquish their U.S. citizenship or terminate their long-term U.S. residence (i.e., U.S. persons who “expatriate”).
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    O.E.C.D. Issues Proposed Changes To Permanent Establishment Provisions Under Model Tax Convention

    On July 11, 2017, the O.E.C.D. Committee on Fiscal Affairs released the draft contents of the 2017 update to the O.E.C.D. Model Tax Convention and the Commentary prepared by the Committee's Working Party 1.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Developments in Offshore Tax Compliance

    Who Has Foreign Accounts and Assets?
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Tax Considerations For A U.S. Holder Of Bare Legal Title In A Usufruct Arrangement

    Ask parents why they work as hard as they do, and many will answer that it is to give their children a better future. For some, this involves sending their children to foreign countries...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    The State Of Expatriation 2011 - Part 1

    Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 ("HEART" or the "Act") dramatically alters the playing field for individuals who relinquish their U.S. citizenship or terminate their long-term U.S. residence (i.e., U.S. persons who "expatriate").
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The Impact Of Select US Tax Reform Provisions On Australian Superannuation Funds And Its Beneficiaries

    Last week, Australian Prime Minister Malcolm Turnbull and President Trump commemorated the first 100 years of mateship between Australia and the United States.
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Taxation Caused By Or After A Change In Residence ~ Part 4

    United StatesWealth Management
    Roberts & Holland LLP
    Roberts & Holland LLP
  • Article

    IRS Targets Malta Pension Plans: Compliance Options

    In recent years the IRS has become aware that U.S. taxpayers are participating in transactions known as "Malta pension plans" (Malta plans). Typically, in these transactions, a U.S...
    GlobalTax
    Gray Reed
    Gray Reed
  • Article

    QDOT-Ting I's And Crossing T's: Estate Tax Planning For Non-United States Citizen Spouses

    Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth.
    United StatesFamily and Matrimonial
    Ward and Smith, P.A
    Ward and Smith, P.A
  • Article

    The New U.S.-Italy Treaty: A U.S. Perspective

    On March 3, 2009, the Italian Parliament approved a new U.S.-Italy income tax treaty, which had been signed on August 25, 1999.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Internet Sales Pose International Tax Challenges

    United StatesWealth Management
    Roberts & Holland LLP
    Roberts & Holland LLP
  • Article

    Proposed Anti-Hybrid Regulations Under Sections 267A, 245A, And 1503(d)

    On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    The World Tax Advisor - July/August 2005 (Recent Asia Pacific Developments)

    Contents: Hong Kong - Court Rules on Source of Brokerage Company's Income, India - Tribunal Rules on Taxability of Service Fees under India-U.S. Treaty / AAR Rules on Application of India - U.A.E. Treaty, Japan - 2005 Tax Law Changes Affect Inbound Investment / New Law May Prohibit Japanese Branch Operations of Foreign Companies, Macau - Government Restricts Activities of Offshore Companies, Philippines - Corporate Tax and VAT Changes Enacted, Taiwan - MOF Issues Rulings on Taxation of Forei
    GlobalStrategy
    Deloitte LLP
    Deloitte LLP
  • Article

    Time For A Change: Toward A New Korea-U.S. Income Tax Treaty

    The United States has 66 bilateral income tax treaties in place. Under these treaties, residents (not necessarily citizens) of foreign countries are generally taxed at a reduced rate or are exempt from U.S. tax on some items of income they receive from sources within the United States.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    When Does E-Commerce Result In A Permanent Establishment? The OECD's Initial Response

    United StatesTax
    Roberts & Holland LLP
    Roberts & Holland LLP
  • Article

    IRS Reproposes Regulations for Taxing the Final Frontier

    The Internal Revenue Service (the Service) has issued reproposed regulations governing the character and source of income derived from communications activities conducted in space and international waters as well as income derived from international communication activities.
    United StatesTax
    DLA Piper Rudnick Gray Cary
    DLA Piper Rudnick Gray Cary
  • Article

    Sound And Fury, Signifying What? The U.S. Foreign Earned Income Exclusion Debate

    Congress possesses the constitutional authority to tax American citizens on their worldwide income.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Showing 501–520 of 525 results

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