This article addresses provisions of the Tax Cuts and Jobs Act of 2017 that affect certain U.S. investors in foreign corporations on a go-forward basis and a one-year transition period for the 2017 taxable year.

After nearly two decades of negotiations, Belgium and France signed a new Income Tax Treaty on November 9, 2021 (the "New Treaty"). The New Treaty is in line with the latest O.E.C.D.

The New York Times reported recently that the National Basketball Association ("NBA") and Major League Baseball ("MLB") are reaching out to both Congress and the Trump administration to learn more...

Following the lead of the O.E.C.D. and the European Commission ("E.C."), the Tax Cuts and Jobs Act ("T.C.J.A.") adopts several provisions designed to end certain tax planning opportunities.

In a previous article for Insights,1 the new British Virgin Islands (“B.V.I.”) beneficial ownership information (“B.O.I.”) reporting regime was considered in the context of wider transparency developments affecting offshore financial centers.

In today's start-up world, angel investing1 is a typical part of an entrepreneur's rou¬tine.

When asking a U.S. tax adviser to describe the "revenue rule," it would not be surprising for the adviser to say that it refers to formal guidance issued by the I.R.S. that can be relied on by other taxpayers as authority for a position taken in a tax return.

If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.

The House plan to tax imports and exempt exports is part of a tax reform package that is expected to raise more than $1 trillion to offset lower income tax rates and improve U.S. competitiveness against global rivals.

Ask parents why they work as hard as they do, and many will answer that it is to give their children a better future. For some, this involves sending their children to foreign countries...

Mr. Z is a U.S. resident under Code §7701(a)(30) for purposes other than the foreign tax credit. He is a Green Card Holder

On July 11, 2017, the O.E.C.D. Committee on Fiscal Affairs released the draft contents of the 2017 update to the O.E.C.D. Model Tax Convention and the Commentary prepared by the Committee's Working Party 1.

In a 21st century America where new ideas continually create new intangible property, U.S. corporations often desire to contribute their I.P. to a foreign affiliate who then develops and...

Tax planners outside the U.S. are often asked to develop plans for clients moving to or investing in the U.S.

In Rev. Rul. 91-32, the I.R.S. announced its view that foreign partners in partnerships operating in the U.S. are properly taxed on their capital gains under a look-thru rule to the assets owned by...

The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced a new anti-abuse tax regime applicable to controlled foreign corporations ("C.F.C.'s").

The Action 14 Report introduced a minimum standard on dispute resolution that must be observed by participating countries to ensure that they resolve treaty-re­lated disputes...

Change driven by development of intellectual property ("I.P.") is now a constant. Whether the I.P. user is a tax adviser accessing a digital library, an auto mechanic interfacing with an engine...

On December 11, 2023, the I.R.S. and Treasury Department issued Notice 2023-55 (the "Notice"), announcing the intention to issue proposed regulations addressing the interaction...

The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").