As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy one of two tests: the green card test or ...

The IRS recently issued Notice 2013-69, providing additional guidance on the implementation of FATCA.

The signing of the MLI represents a significant milestone for the OECD's BEPS project.

his article will explore two cases where arbitration under a B.I.T. provided ephemeral benefits.

On 1 September 2010, the new Double Taxation Treaty Passport ("DTTP") scheme became operative. According to Her Majesty’s Revenue & Customs ("HMRC") the new scheme will result in expedited treaty clearances and will provide a simpler and more efficient method of paying interest to overseas lenders, which has been sought after by businesses as an alternative to the present certified claim procedure for some time.

On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.

With all due respect for persons who are involved in, interested in, or just cognizant of the U.S. tax treaty program — which is one way of referring to the efforts of the Treasury...

On 23 November 2022, the Dutch Ministry of Finance issued a new Decree outlining its position on the application of tax treaties and domestic withholding taxes in light of hybrid situations...

In the uncertain economic environment post Brexit, US citizens and green card holders living in Britain may have questions regarding how their US tax and reporting obligations may have changed.

On 22 March 2022, the Organisation for Economic Co-operation and Development ("OECD") published a public consultation document proposing new and amended reporting requirements with respect to...

Contrary to common belief, a foreign, international or interstate business, including a foreign subsidiary of a domestic company, may have a state tax liability even if such business does not have an office in a state, but it has an employee, agent or third-party representative traveling into a state. Similarly, having consigned inventory, leased property, intangible or tangible property or other types of presence in a state can subject a foreign, international or interstate business to state ta

Recognizing the inexorable globalization of business and underscoring the high priority that top management places on international tax compliance, the IRS just announced a realignment of its Large and Mid-Size Business (LMSB) division into a new Large Business and International division (LB&I) [See IRS press release].

•International Tax Review: Leading Women in Tax Forum: Ropes & Gray is a sponsor of the ITR: Leading Women in Tax Forum on March 3 in New York,...

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

Senator Thom Tillis introduced a bill (called the "Tackling Predatory Litigation Funding Act") that would impose additional significant taxes on litigation funding investments.

The Amendment will enter into force on the first day of the month following the completion of the reciprocal notification process attached to its ratification in each of France and Luxembourg.

From 1 January 2017, jurisdictions that have not brought their Intergovernmental Agreement (IGA) into force will no longer be seen to have an IGA, in the eyes of the US Department of Treasury.

The IRS has introduced a new Automatic Exemption from Penalty program while a federal court struck down key GILTI regulations in a significant post-Loper Bright decision. The Treasury and IRS also finalized guidance on life insurance contract transactions and updated various energy-related tax credits and reporting requirements.

On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey's Corporation Business Tax ("CBT"). The bill enacted a variety of clarifications, corrections, and modifications to the CBT.

On December 22, 2021, the European Commission adopted a draft Directive laying down rules to prevent the misuse of shell entities for tax purposes (COM/2021/565 final)...