Over the past few years, global financial regulators and treasury departments have continuously sought out new ways to expose individuals engaged in cryptocurrency transactions.

In connection with income from the performance of services, non-U.S. individuals are subject to U.S. tax only on U.S.-source income.

At a Washington tax conference on May 20, Treasury Assistant Secretary for Tax Policy Kenneth Kies reportedly signaled that anti-stacking regulations targeting Code §1202 qualified small business stock (“Q.S.B.S.”) are likely forthcoming.

The I.R.S. recently issued the first of a set of what is expected to be several sets of proposed regulations to provide greater clarity on the application of information-reporting rules.

In finding for the taxpayer in a recent transfer pricing decision, the U.S. Tax Court followed its own determination in Veritas in valuing a buy-in payment made as compensation...

In previous articles we have discussed the relative flexibility of limited liability companies ("L.L.C.'s"), which are generally taxed as partnerships ...

The Large Business and International Division of the I.R.S. ("LB&I") periodically develops international practice units ("I.P.U.'s") that serve as training material ...

In E.S. N.P.A. Holding L.L.C. v. Commr., 1 the U.S. Tax Court decided that the indirect receipt of a profits interest in a partnership in exchange for services...

On April 21, 2017, President Trump issued Executive Order 13789 (the "Order") with the objective of identifying and reducing tax regulatory burdens imposed by Treasury Regulations (the "Regulations").

It is not uncommon for a young adult who was born in the U.S. to noncitizen parents living temporarily in the U.S. to live abroad.

Many U.S. investors and business owners are familiar with the tax exemption provided to U.S. individuals recognizing gains from the sale of certain...

Many foreign grantors establish foreign trusts to benefit themselves and their foreign beneficiaries. It is not uncommon, however, for a foreign beneficiary to relocate to the United States.

On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code §965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders...

In purely domestic situations, the Internal Revenue Code (the "Code") provides for the deferral of taxation when certain corporate reorganizations or transactions...

The I.R.S. recently issued Notice 2018-28, announcing that it intends to release regulations on various issues pertaining to the limitation on the deductibility of certain interest payments...

A trust is an instrument having extreme flexibility and adaptability. For those reasons, it is becoming more and more common in the field of estate and succession planning as a simple...

Nothing is certain in this world, except death and taxes – and even taxes are subject to change.

In Franklin v. U.S., the Fifth Circuit recently upheld the constitutionality of Code §7345, a provision of the Code that was in 2015.

Earlier this year, the I.R.S. updated its Transfer Pricing Documentation Best Practices F.A.Q. list with a response to Q. 4, What are some areas the I.R.S. has identified in transfer pricing...

When a Mosotho or a Sesotho speaker says "stay together," they usually mean "live together." By this terminology, the Inclusive Framework of 137 countries that agreed in October...