The "Requirement to Correct" ("R.T.C.") rules became law when the Finance (No. 2) Act 2017 received Royal Assent on November 16, 2017.

For U.S. tax purposes, gain or loss upon a sale or exchange of property is generally sourced based on the tax home of the seller. For a foreign person investing in a partnership...

As of last September, China has begun sharing taxpayer financial information of residents and nonresidents with over 100 countries under the Common Reporting System ("C.R.S.").

The limitation of interest deductibility to approximately 30% of E.B.I.T.D.A. (earnings before interest, tax, depreciation, and amortization) introduced in amended Code §163(j) has focused the attention of U.S. corporations ...

A U.S. taxpayer that is subject to income tax in both the U.S. and a foreign country can reduce the amount of tax payable to the U.S. by claiming a credit for foreign income taxes paid or accrued...

A prior article in this series discussed the way U.S. estate tax is imposed on the transfer of artwork at the time of death.

The comedian, Mel Brooks, once uttered a quip for the ages: "It's good to be king!" The thrust of the statement was that those in power can do what they want.

When claiming a refund of over-withheld tax, purchasing or selling real property, or complying with U.S. filing requirements, a non-U.S. individual is required to obtain an I.T.I.N. from the I.R.S...

The Bank Secrecy Act ("B.S.A.") requires U. S. persons with certain financial interests in foreign accounts to file an annual report known as an "F.B.A.R.," which is embodied

This article looks into some important tax considerations for an individual planning to start a U.S. business.

Because most U.S. States do not require information about the beneficial owners of an entity, and with more than two million entities being formed in the U.S. each year...

As the transfer pricing travails of Eaton Corporation ("Eaton") continue, a recent U.S. Tax Court decision affirmed that (i) I.R.S. administrative rules set down in rev¬enue procedures...

educing perceived wealth disparity in the United States has become a major political goal of the Biden Administration and the Democratic Party.

Obtaining an I.TI.N. is done by completing Form W-7, Application for I.R.S. Individual Taxpayer Identification Number.

Section 245A of the Internal Revenue Code of 1986 (the "Code") effectively exempts U.S. corporations from U.S. Federal income tax on dividends received from certain foreign subsidiaries.

The I.P.U. acknowledges that exceptions are provided for small corporations and transactions of de minimis value.

Forming a Delaware corporation or LLC is simple, but maintaining proper internal records often becomes an afterthought until lenders, purchasers, or investors request them. This article examines the essential ancillary documents—from certificates of formation to subscription agreements—that companies without internal legal departments frequently overlook, and explains why proper record-keeping matters for future transactions.

In the Tax Cuts and Jobs Act of 2017, Pub. L. No. 115-97, the U.S. Con¬gress enacted the most dramatic change to the U.S. Tax Code since 1986, adding among other provisions G.I.L.T.I.'s quasi-territorial tax under Code §951A.

Generally, a partnership is treated as an aggregation of its partners, meaning a flow-through treatment applies as to the partnership's income. However, for certain purposes, a partnership...

Due to concerns about the potential use of foreign trusts and gifts as a means to access the proceeds of unreported income, the Internal Revenue Code (the "Code") and related regulations...