Legal 500
  • Rankings

    • Jurisdictions

    • Submissions

    • Future Lawyers

  • Firms & Lawyers

    • Service Providers

    • Barristers’ Sets

    • Networks

    • Interview with…

  • In-House

    • In-House Content

    • GC Powerlist

  • Knowledge Centre

    • Data Products

    • Legal Business

    • News & Developments

    • About us

      • Legal 500

      • FAQs

      • Marketing

      • Careers

      • Contact us

  • Comparative Guides

  • Events

  • Legal 500 TV

About us

  • Legal 500

  • FAQs

  • Marketing

  • Careers

  • Contact us

  • Deutschland DE

  • Paris FR

  • Rankings

    • Jurisdictions

    • Submissions

    • Future Lawyers

  • Firms & Lawyers

    • Service Providers

    • Barristers’ Sets

    • Networks

    • Interview with…

  • In-House

    • In-House Content

    • GC Powerlist

  • Knowledge Centre

    • Data Products

    • Legal Business

    • News & Developments

    • About us

      • Legal 500

      • FAQs

      • Marketing

      • Careers

      • Contact us

  • Comparative Guides

  • Events

  • Legal 500 TV

About us

  • Legal 500

  • FAQs

  • Marketing

  • Careers

  • Contact us

  • Deutschland DE

  • Paris FR

© 2026 Legalease Ltd. All rights reserved

Registered company in England & Wales No. 02427356 VAT GB 321 5727 22

Registered address: 188 Fleet Street, London, EC4A 2AG

  • Data Protection policies
  • Cookies Policy
  • Contact Us
  • Article

    French Social Security Charges (C.S.G. And C .R.D.S.) Are Creditable

    As stated in our June 19 Client Alert, the French contribution sociale généralisée and contribution au remboursement de la dette sociale previously were not considered creditable foreign income taxes ...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    U.K. Mandatory Disclosure Regime (DAC6)

    The E.U. Council Directive 2018/822 ("DAC6") provides for the mandatory disclosure by intermediaries, or individual or corporate taxpayers, to H.M.R.C.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    How Not To Borrow A Treaty: Smith v. Commr.

    On a fully distributed basis, profits of a corporation are taxed twice. First, profits are taxed at the corporate level.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    F.I.R.R.M.A. Proposed Regulations Expand C.F.I.U.S. Oversite On Foreign Investment

    On August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 ("F.I.R.R.M.A.") was signed into law after receiving broad bipartisan support in Congress.
    United StatesGovernment, Public Sector
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    U.S. Taxation Of Cloud Transactions And Digital Content Transfers: 20-Year-Old Regulations Finally Move With The Times

    To put things in perspective, when the -18 Regulations were adopted, a typical internet connection could download 1GB in approximately 48 hours.
    United StatesMedia, Telecoms, IT, Entertainment
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Happy Ending For The Home Of The Happy Meal – No Illegal State Aid To McDonald's

    On September 19, 2018, the European Commission issued a decision that nontaxation of certain McDonald's profits in Luxembourg was not illegal State Aid.
    GlobalAntitrust/Competition Law
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Domestic Partnerships Treated As Entities And Aggregates: New Approach For G.I.L.T.I. And Subpart F

    The effect of the T.C.J.A. continues to be encountered in unexpected ways during the second year after its enactment.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Updates & Other Tidbits

    Recent tax developments include New York City's new property tax surcharge on high-value pied-à-terre homes and potential changes to IRS Form 1040 that would require disclosure of citizenship status and dual citizenship. These policy shifts reflect growing efforts to address tax equity in luxury real estate markets and enhance transparency in tax reporting for individuals with complex international ties.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Preferred Yet Neglected — A Plea For Guidance On Redemptions Of C.F.C. Preferred Stock In The Wake Of U.S. Tax Reform

    Neglected preferred stock! Yes, this article begins with an oxymoron.
    United StatesCorporate/Commercial Law
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Cristiano Ronaldo's Move To Italy – Was It For Love Of The Game Or The Tax Law?

    Colombian singer Shakira, was also ordered to pay more than €20 million in back taxes to Spain
    ItalyTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Commentary On New Canadian Transfer Pricing Legislation

    The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Investing In U.S. Real Estate On A (Possibly) Tax-Free Basis

    Real Estate Investment Trust ("R.E.I.T.") is an entity that generally owns and typically operates a pool of income-producing real estate properties, including mortgages.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Partner Representatives And The New Partnership Audit Regime

    Commencing in January 2018, the I.R.S. began a new centralized audit regime with respect to partnerships. It replaces the concept of a "Tax Matters Partner" with a "Partnership Representative.
    United StatesAccounting and Audit
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Does Powell Offer Taxpayers Meaningful Protection In Cross Border E.O.I. Requests?

    In Through the Looking-Glass, by Lewis Carroll, Humpty Dumpty makes the following point when speaking to Alice
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Saving Clementine: Improving The Code §163(J) Deduction

    Oh my darling, oh my darling, oh my darling, Clementine, You are lost and gone forever, dreadful sorrow, Clementine.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Insights Volume 12 Number 1: Updates & Other Tidbits

    Will they or won't they? The end of 2024 and beginning of 2025 have seen continuous back and forth about the Corporate Transparency Act...
    United StatesCorporate/Commercial Law
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    S.A.L.T. Cap Repeal Case Dismissed

    Married individuals filing separately are capped at $5,000.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Earning My Credits: Life At Ruchelman P.L.L.C.

    Credits and externship credits co-mingled during my time at Ruchelman P.L.L.C. While I sought to gain externship credits and learn about the tax world, I spent a lot of time learning about tax credits...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    European Parliament Extends Scope Of Country-By-Country Reporting

    With the objective of enhancing transparency and public scrutiny on corporate income tax, the European Commission adopted a proposal.
    European UnionTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    When The (Fake) I.R.S. Calls – Memoirs Of The Tax Phishing World

    You may have heard the warnings before: Each tax season, the I.R.S. issues guid¬ance urging taxpayers to watch out for new and evolving phishing schemes intend¬ed, in one way or another...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC

Showing 21–40 of 263 results

PreviousNext
Legal Intelligence Newsletters