The Tax Cuts and Jobs Act ("T.C.J.A.") introduced Code §59A, which imposes a new Base Erosion and Anti-Abuse Tax ("B.E.A.T.") on large corporations that significantly reduce their U.S. tax liability ...

New York City's public transportation system is old and in desperate need of significant renovation.

Since recent Federal tax law changes have capped the state and local tax deduction for individuals to $10,000, many states have been trying to implement solutions

When a U.S. person disposes of a business situated in a foreign country, the nature of the gain as capital or ordinary and the source of the gain may sound

On October , the "other shoe dropped" on eight regulations issued by the Obama administration in 2016 and January 2017.

Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities ...

The I.R.S. has announced that it disagrees with the ruling in Bartell v. Commr.1 in an Action on Decision ("A.O.D.") issued on August 14, 2017, expressing its "nonacquiescence" with the case.

The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.

Federal tax law has introduced a new type of gross income. The provisions applicable to Global Intangible Low Tax Income ("G.I.L.T.I.") are designed to stop U.S.

The O.E.C.D. announced on January 31, 2020, that its policy development efforts under Pillar One, related to the taxation of the digital economy, will move forward using the non-consensus...

The political battle between the Democrats in the House of Representatives and President Trump concerning the release of tax returns has moved to the courts.

A recent decision, involving Starr International Company ("Starr"), provides insight into what a court may view as relevant in deciding a treaty shopping case.

Often the realities of a business arrangement can be quite different than a plan conceived between optimistic partners. Market conditions can change...

Under Code §962, an individual U.S. Shareholder may elect to be treated as a domestic C-corporation for the purpose of computing income tax on its share of Subpart F Income.

When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.

In response to the O.E.C.D.'s B.E.P.S. recommendations and the conclusions and concerns identified by the E.U. Code of Conduct Group of Business Taxation,

The I.R.S. Large Business and International division ("LB&I") recently announced the approval of the following six additional compliance campaigns:

On Friday, May 22, 2025, the U.S. House of Representatives adopted a budget resolution containing provisions that would impose increased taxes for persons based in countries that impose taxes...

The Tax Cuts and Jobs Act ("T.C.J.A."), signed into law on December 22, 2017, contained several major changes with respect to individuals and entities.

On March 3, 2017, the U.S. Court of Federal Claims ruled that a taxpayer's liability for the domicile levy in Ireland does not qualify him as a resident of the country under the U.S.-Ireland Income Tax Treaty.