This month finds the arm's length principle continuing to operate among O.E.C.D. Member States and the broader inclusive framework working toward international tax reform of the digitized economy.

In IR-2018-131, issued on June 4, 2018, the I.R.S. announced that it will waive certain late-payment penalties relating to the Code §965 transition tax ...

On the way toward a dividends received deduction for certain dividends paid by foreign subsidiaries, Congress enacted a one-shot income inclusion of all post-1986 earnings...

President Trump made several tax proposals in the course of his winning campaign for the White House. Here is a list of those proposals and the likely response of Democrats in Congress followed by a general.

On October 31, 2018, the I.R.S. proposed regulations affecting controlled foreign corporations ("C.F.C.'s") and U.S. corporations that are considered to be U.S. Shareholders ...

The tax press often champions the value of tax transparency. However, as tax information reporting obligations grow, many taxpayers find that the penalties for inadvertent errors can exceed the tax, ...

When non-U.S. entities expand to the U.S., they face several issues, all of them new.

Recently, the Court of Appeals for the D.C. Circuit affirmed the 2017 Tax Court ruling in the matter of Grecian Magnesite Mining v. Commr., which held that a foreign corporation was not liable for U.S. tax on the gain ...

The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.

U.S. estate tax planning is said to be among the most complicated aspect of tax planning because of the numerous moving parts and the changing needs and objectives of the family.

The 2017 Tax Cuts and Jobs Act introduces a new tax regime applicable to con¬trolled foreign corporations ("C.F.C.'s").

Like most assets developed, used, and sold in business, intellectual property (IP) is subject to important tax considerations.

When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure...

The Internal Revenue Code (the "Code") provides a foreign earned income and housing cost exclusion to qualified individuals, subject to some limitations set out in Code §911(b)(2).

Regardless of their political affiliations, presidential administrations and members of Congress share the goal of maintaining U.S. competitiveness on the global market.

On Friday, March 21, 2025, the Financial Crimes Enforcement Network ("FinCEN") of the Treasury Department published interim final rule to narrow the existing beneficial ownership information ("B.O.I.")...

Instead of following the standard I.R.S. approach1 for cases where Code §2036(a) was applied, which was never contested, the court adopted a new, untested theory– one that could potentially create...

The arrival of an information document request ("I.D.R.") for transfer pricing documentation often comes as a surprise to a company.

A trust is a relationship (generally a written agreement) created at the direction of an individual (the settlor), in which one or more persons (the trustees) hold the individual's property subject...

U.S. persons are required to file Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) with the I.R.S. to report...