In today's global environment, it is not surprising to find that a beneficiary of a foreign estate or trust is living in the U.S.

If a person thinks one thing but says another, what are others to believe? Statutory interpretation often favors the latter over the former.

While the U.S. still refuses to sign onto the O.E.C.D.'s Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the "CbC M.C.A.A."), the I.R.S. is making progress...

Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").

Every cloud has a silver lining. This expression also applies to the world of tax. Troubled companies that incur significant operational and interest expenses may find that they have generated...

A robust and extensive income tax treaty network has worked to the advantage of U.S. corporations and individuals.

U.S. real estate remains a favored asset class for foreign investment by Israeli residents. With the Israeli shekel currently being relatively strong against the U.S. dollar, investments in the U.S.

When it comes to pre-immigration planning, there are greater opportunities when the individual moving to the U.S. is not yet a U.S. person for U.S. tax purposes: Various techniques are available...

No, we are not talking about our favorite Marvel comic superhero, friendly neighborhood Spider-Man!

The application of the foreign tax credit to the net investment income tax ("N.I.I.T.") has been a recurring battle in courtrooms in recent years. In the most recent installment...

The I.R.S. recently released drafts of two new partnership return schedules and accompanying instructions to replace, supplement, and clarify the way partnership income, loss, deductions, credits and other items ...

Using deductible interest payments to reduce U.S. taxable income is often a goal of tax practitioners.

For many years, the U.S. government has been concerned about U.S. businesses reducing or deferring U.S. income tax liabilities through the use of foreign corporations.

Alan Greenspan is an American economist who served as the 13th chairman of the U.S. Federal Reserve from 1987 to 2006. He is known to have authored the following quote...

While determining whether a taxpayer has complied with its obligation to provide the I.R.S. with information on its international operations as required by Code §6038 for outbound transactions and by Code §6038A...

In 2018, Delaware amended its limited liability company act to add Section 18-217, which enables an L.L.C. to divide into two or more newly formed L.L.C.'s, with the dividing company either continuing or terminating its existence.

The foreign tax credit ("F.T.C.") is a keystone of U.S. outbound tax legislation.

As promised before the end of 2024, Treasury and the I.R.S. outlined their approach to the codification of Amount B, a component of the O.E.C.D. Pillar One approach1 ("O.E.C.D. guidance")...

The first step in advising a foreign individual who is neither a U.S. citizen nor a green card holder on U.S. income tax laws is to determine the person's residence ...

The Johannesburg Tax Court reached a similar conclusion, albeit along a different path, in a case that addressed a matter involving a U.S. service provider.