In representing a taxpayer interested in purchasing a business, it is important for tax counsel to understand, in simple terms, what each party is seeking to accomplish.

Two transfer pricing cases, in Australia and in Canada, address arm's length transfer pricing methodology for mined minerals during a period of steep increases in spot prices. In each case

When financial analysts of a financial institution review the tax provision of potential customers incident to a financial transaction, the focus typically is directed at current and deferred taxes...

On June 25, the Senate Foreign Relations Committee approved protocols to four income tax treaties, clearing the way for the treaties to be considered by the full Senate.

Companies and financial institutions are not liable for inheritance tax and therefore do not face additional tax.

Except for the U.S., transfer pricing law frequently includes a provision that references the O.E.C.D. T.P. Guidelines as the guidance that must be used to interpret other provisions of relevant law.

How many times have we watched a movie, read a book, or listened to a colleague talk about an action that appeared to be a no-risk proposition, only to turn into a nightmare?

Mr. Baron was extradited to the U.S. from Hungary in July.

They do not apply the B.E.P.S. minimum standards, nor have they committed to address these issues by the E.U. deadline, December 31, 2018.

Tax authorities that are tasked with tracking down tax evaders and their enablers take their jobs seriously. When success against tax evaders is encountered, two benefits are obtained.

The new limitation on the deduction will increase the cost of owning a home, which will in turn depress home values.

While a French-U.S. perspective is reflected in this article, most foreign tax lawyers practicing in the U.S. may find part of their own experience mirrored here.

Generally, Federal estate and gift taxes are imposed on a person's right to transfer property to another person during life or upon death.

The Tax Cuts and Jobs Act ("T.C.J.A.") brought many changes for non-corporate taxation, changing tax rates and repealing many popular deductions.

The I.R.S. announced it will slowly launch a passport denial program with the U.S. State Department beginning in January 2018.

Aroeste v. United States1 is a court case that previously drew attention because the court, based on a plain reading of statutory language, overturned I.R.S. policy that residency...

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 ...

his article will explore two cases where arbitration under a B.I.T. provided ephemeral benefits.

On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.

Federal returns that are submitted in 2018 with an expired I.T.I.N. will be processed.