The year 2025 marks the 45th anniversary of the enactment of the Foreign Investors Real Property Tax Act. It is a good time to revisit issues that are faced by nonresident investors considering...

This article will review the basic U.S. Federal tax considerations of intellectual prop¬erty ("I.P.") taxation in the context of corporations and partnerships and examine some typical tax considerations...

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes as European profits were generated, (ii) the integration of European tax plans with U.S. tax concepts to prevent Subpart F from applying to intercompany transactions in Europe, and (iii) the reduction of withholding taxes and U.S. tax under Subpart F as profits were distributed through a chain of European companies and

Lastly, U.S. citizens living in Switzerland will benefit from the increased lifetime exclusion amount so that fewer individuals will be subject to estate tax in the U.S.