Congratulations. Your Israeli start-up is doing well enough for you to consider expanding operations to the U.S. market. Now what? The list of things to think of is endless...

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning "syndicated conservation easements." The key features of the offer include a 10% penalty for gross valuation misstatement, instead of a 40% penalty, and no upfront payment required.

Remote work is one of COVID-19's enduring legacies. What began as something necessary for health and safety has become a fairly conventional practice.

The U.S. person must prepare a valuation of the intangible property in accordance with rules set forth in the Treasury regulations.

If all currencies were pegged to one single standard and did not fluctuate in value among themselves, the concept of currency gain and loss would not be needed.

On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code §199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.

In upholding a lower tax court's decision, the German Federal Tax Court held that repayment of capital by a U.S. subsidiary to its German parent company would be non-taxable under German tax law.

A sale of a business to a buyer often involves an element of goodwill, a term that can have different meanings in different contexts, depending on whether the term relates...

The U.S. tax system is a "self-assessment" model: upon determining how tax provisions apply to their transactions, taxpayers pay any tax due, and report the transactions to the I.R.S...

Foreign students leaving their home country and arriving in the U.S. for higher education may come across many things that seem alien to them – like the accent, culture, (inexplicably large) food portions, etc.

On May 3, 2017, the I.R.S. issued Rev. Rul. 2017-09, 2017-21 I.R.B. 1244, which clarifies "north-south" transactions in two factual situations.

The segment of European countries that have enacted favorable tax regimes designed to attract the wealthy are well known. Switzerland has its forfait regime, the U.K. has its Nondom Tax...

A participating F.F.I. files Form 8966, F.A.T.C.A. Report, annually with the I.R.S. The

The current international tax system was established at a time when the sharing economy did not exist and was not foreseeable.

Congress enacted the N.I.I.T. in 2012 as part of a 2010 law amending the Affordable Care Act ("A.C.A."), more popularly known as "Obamacare." Its creation corresponded to a 0.9% increase...

At a certain point in the life of a corporation that operates more than one business, management may wish to separate the different businesses into two or more separate...

"Doe normaal" is practical advice in the Netherlands encouraging one to act normal. In the past, that phrase would describe commonly used plans to reduce tax.

As explained in an earlier article,1 a common civil law estate planning technique involves an older generation making a gift of bare ownership in an income generating asset to members of a younger generation.

On August 11, 2017, the O.E.C.D. released comments on the draft 2017 updates to the O.E.C.D. Model Tax Convention prepared by the Committee's Working Party 1 and published on July 11, 2017.

There has been a wealth of conversation addressing the amendment to the definition of a "U.S. Shareholder" in the context of a controlled foreign corporation introduced by the 2017 Tax Cuts and Jobs Act.