The Federal Taxpayer Identification Number ("T.I.N.") used by entities is the Employer Identification Number ("E.I.N."). The E.I.N. application (both online and using Form SS-4)

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

At first, it may seem that the I.R.S. was harsh in determining that the taxpayer missed his chance to contest the F.P.A.A. for the two partnerships he held indirectly through another partnership.

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...

A recent Tax Court Memorandum decision, involves the valuation of two Old Mas¬ters paintings for estate tax purposes. An expert at a famous auction house was retained by the estate.

On December 13, 2018, the I.R.S. issued proposed regulations under Code §§1471 through 1474 (F.A.T.C.A provisions) as well as under Code §§1441 and 1461 (withholding on non-U.S.

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with ...

While some activities are limited when working from home during a global lockdown, there are still a variety of tax-efficient options available to sell foreign real property.

The purpose of the most recent decision in the Medtronic saga extends and refines the prior analysis of one of five connected controlled transactions within Medtronic's controlled group of multinational medical device producers and suppliers.

The financing of acquisitions involving Dutch companies has come under increased scrutiny in the Netherlands in recent years. The Dutch Tax Authority ("D.T.A.")...

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:

A participation exemption is a feature of many territorial systems and eliminates incremental tax on foreign-source income.

The reliance on smartphone G.P.S. applications is nearly ubiquitous in today's world. These "map apps" not only furnish diverse routes to destinations...

In an article published in Insights in 2022, the following comment was made regarding two seemingly never-ending transfer pricing battles being conducted...

Imagine a straight line. Now assume that it represents a timeline – a timeline that divides the tax world into the pre and post T.C.J.A. era. You know the magic date, December 31, 2017.

The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...

If a statement was filed and no one reads it, was it filed at all? That is the uncomfortable question many taxpayers will be asking after Daniel Price, a long-time I.R.S. attorney...

In Europe, an individual's right to the protection of his or her personal data is a fundamental right.

Not all is exciting when a foreign student gets a job offer from a U.S. employer under the Summer Work Travel Program administered by the U.S. Department of State

The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced two new rules targeting hybrid arrangements. The first deals with hybrid dividends.