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  • Article

    Cryptocurrencies - Latest Developments On Either Side Of The Atlantic And Beyond

    What is needed is an electronic payment system based on cryptographic proof instead of trust, allowing any two willing parties to transact directly with each other without the need for a trusted third
    United StatesTechnology
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    The Sharing Economy Part 1:New Business Models +Traditional Tax Rules Don't Mix

    The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    B.V.I.: Beneficial Ownership Reporting And Consultation On Access To Beneficial Ownership Information

    In an article published in Insights last year,1 selected developments in regulatory and tax-related law and practice that affect end-clients, advisors and intermediaries were surveyed in the British Virgin Islands ("B.V.I.").
    British Virgin IslandsCorporate/Commercial Law
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    A C.T.A. Of The C.T.A. – A Closer Targeted Analysis Of The Corporate Transparency Act

    On January 1, 2021, Congress passed the Corporate Transparency Act (C.T.A.) as part of the National Defense Authorization Act.
    United StatesCorporate/Commercial Law
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Dynasty In The Details – U.S. Estate Planning Considerations For Global Families

    In the United States, creating "dynasty trusts" has become common planning tool for many estate planners. A dynasty trust is a trust that may continue for generations under applicable law.
    United StatesFamily and Matrimonial
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Global Tax Planning In A Pre-2018 World

    Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Global Tax Planning In A Pre-2018 World

    Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations:
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Can The Arm's Length Standard Beat The R.A.P.? Transfer Pricing After The T.C.J.A.

    By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Outbound Acquisitions:Holding Companies Of Europe – A Guide For Tax Planning, Or A Road Map For Difficulty?

    When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Anti-Inversion Rules Are Not Just For Mega-Mergers – Private Client Advisors Take Note

    Transactions known as corporate "inversions" or "expatriations" have made headlines for years.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    The Economic Substance Doctrine: A U.S. Anti-Abuse Rule

    Major corporate transactions typically reflect at least two separate elements. One is the business arrangement agreed to by the parties.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Value-Added Tax 101 – A Far Cry From A Border Tax

    Although the U.S. is the world's largest economy, it is the only world economy that does not have a value-added tax ("V.A.T.").
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    European Commission Proposes New Advisor Disclosure Obligation For Aggressive Tax Planning

    In the current context of tax transparency, fair and effective taxation, and global tax good governance, the European Commission recently pushed existing disclosure obligations one step further.
    European UnionTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Foreign Investor In A U.S. L.L.C. – How To Minimize Withholding Tax On Sale Of L.L.C. Interest

    On April 2, 2018, the I.R.S. published Notice 2018-29 (the "Notice"), describing Treasury Regulations it intends to issue with regard to the new withholding requirement on transfers of partnership interests ...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Blockchain 101

    Blockchain has recently been in the spotlight, mostly due to the 2017 surge in cryptocurrency values and the rise of initial coin offerings ("I.C.O.'s").
    United StatesTechnology
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    When Does An Aged Account Receivable Give Rise To A Deemed Repatriation?

    Arrangements to shift formal voting power away from U.S. shareholders are not giv¬en effect if voting power is retained in reality.
    United StatesCorporate/Commercial Law
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    F.B.A.R.'s – What You Need To Know

    April 15 is almost here, and while most people know this date as the filing deadline for individual tax returns, it also important to another filing requirement:
    United StatesFinance and Banking
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Foreign Tax Credit May Not Be Available For Gains Derived Outside The U.S.

    The U.S. applies a worldwide tax system imposed on residents and citizens alike.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Modifications To The Foreign Tax Credit System Under The Tax Cuts And Jobs Act

    One of the principal revisions to U.S. tax law made by the TCJA involves the way U.S. tax law avoids double taxation when a foreign subsidiary distributes a dividend to a U.S. corporation...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Tax 101: Taxation Of Equity-Based Compensation And Cross Border Issues

    Equity-based compensation has long been a popular way to attract talent and align the interests of corporations and service providers.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC

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