Five-time Super Bowl champions the New England Patriots have earned a new title: the first team in NFL history to buy their own fleet of planes.

In early April, Bloomberg News reported on coordinated tax raids on three separate offices of Credit Suisse.

In the procedural maze that leads to a trial in the U.S. Tax Court, motion practice is an important part of tailoring issues presented to the court.

When a married couple resides in a civil law jurisdiction, their marital property is typically governed by community property principles – rules that automatically characterize most assets acquired during marriage...

Flow-through entities raise the question of when the entity stands in its own name versus being a collection of its owners.

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 YA Global case has drawn widespread attention due to the U.S. tax implications for foreign investment entities investing in U.S. securities or making use of a U.S. investment manager.

The clock is ticking for "Opportunity Zones," and the I.R.S. is aware.

When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.

Splitting ownership into usufruct and bare ownership is a common estate planning technique in several civil law countries.

In Grecian Magnesite Mining, Industrial & Shipping Co., S.A. v. Commr.,1 the U.S. Tax Court recently held that a foreign partner was not subject to U.S. Federal tax when it redeemed its interest in a U.S. partnership...

In the realm of taxation, keeping abreast of changes can make a significant difference in how companies and individuals manage their finances.

As more families live, invest, and hold assets across multiple countries, estate plan ning increasingly requires coordination between legal systems that are not designed to work together.

Effective January 1, 2018, Italy's 2018 Budget Law significantly amended the domestic definition of permanent establishment and implemented certain O.E.C.D. guidelines set forth under B.E.P.S. Action 1...

The U.S. Federal, state, and local governments typically offer tax benefits to businesses to encourage economic growth and investment in certain industries and geographic areas.

In October, the U.S. District Court for the Western District of Texas struck down a provision under temporary anti-inversion regulations for violating the required notice and comment period...

The IRS has intensified scrutiny of partnership basis-shifting transactions that manipulate inside and outside basis rules to generate tax savings. While recent regulations were withdrawn under the Trump Administration, the agency maintains its position through Rev. Rul. 2024-14, which identifies three transaction types that fail the economic substance doctrine.

In 2018, charitable giving in the U.S. totaled over $427 billion. Of that amount, 68% of that giving came from individuals, 18% from foundations, 9% from bequests, and 5% from corporations, according to Giving USA.

This article explains important provisions of the Corona Virus Aid, Relief, and Economic Security Act ("CARES Act" or "Act") signed into law on March 27, 2020.

While the word "basket" may trigger a mental image of a bicycle with a daisy basket that is a gift in early childhood, the term has a totally different connotation in the tax world. It denotes "foreign tax credit baskets" to an international tax geek in the U.S.