Initial coin offerings ("I.C.O.'s") offer blockchain-based1 companies a new way to raise capital.2 Companies, both in the U.S. and outside the U.S., have been raising capital using blockchain...

Among the slew of changes in tax law from the One Big Beautiful Bill ("O.B.B.B.") are increased benefits to taxpayers who own "Qualified Small Business Stock" ("Q.S.B.S.").

Incurring economic losses is rarely a good thing. On the other hand, harvesting a capital loss in the same tax period an unrelated capital gain is recognized has its advantages – the loss...

The common law revenue rule is a judicial doctrine that prevents courts in one country from being used by a foreign government as a tool to collect lost tax revenue of any kind. As explained by one...

The painting you bought when you were a student may worth something today. Or maybe you have accumulated a collection of artwork that has a significant value.

This article focuses on the interaction between certain hybrid mismatch provisions of A.T.A.D. 2 and certain provisions of U.S. tax law.

Today's cross border tax planners are expected to know all there is about various provisions of Subchapter N of the Internal Revenue Code.

The economic substance doctrine in the U.S. has its roots in case law that aimed to deny tax benefits generated from certain abusive transactions entered into solely or primarily to obtain tax benefits.

Imagine a lush green garden on a bright sunny day.

In 2013 a new investment scheme was introduced to the world by Y Combinator, a well-established start-up companies accelerator. A Simple Agreement for Future Equity ("S.A.F.E.")...

On December 22, 2017, the Tax Cuts and Jobs Act 2017 ("T.C.J.A.")1 introduced the foreign derived intangible income

Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax

The use of virtual currency is on the rise, and investors and government agencies are taking notice.

In an Action on Decision ("A.O.D.") published in late 2019, the I.R.S. announced its nonacquiescence to the Tax Court's decision in Greenteam Materials Recovery Facility v. Commr.

As explained in the January 2017 edition of Insights, the end of the year in France is always marked by a fiscal legislative process to amend the current year's finance law ...

As the O.E.C.D. continues its work on the taxation of the digital economy, comments were accepted by the O.E.C.D. Centre for Tax Policy and Administration Secretariat in advance of a public consultation in late November 2019.

One of the principal revisions to U.S. tax law made by the Tax Cuts and Jobs Act ("T.C.J.A.") was a series of changes to the definition of the term Controlled Foreign Corporation ("C.F.C.").

In a Code § 351 exchange, the transferee corpora- tion's basis in the contributed IP will be the same as that of the transferor shareholder.

Foreign owners of single-member U.S. limited liability companies often assume their entities are completely disregarded for tax purposes, but since 2017, these structures face significant reporting obligations...

This article addresses the G.I.L.T.I. rules that currently are in effect in the U.S. when a U.S. Shareholder of a C.F.C. engaged in an active business...