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By Beate Erwin
What is needed is an electronic payment system based on cryptographic proof instead of trust, allowing any two willing parties to transact directly with each other without the need for a trusted third
By Galia Antebi, Hannah Daniels
To put things in perspective, when the -18 Regulations were adopted, a typical internet connection could download 1GB in approximately 48 hours.
By Simon H. Prisk
On August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 ("F.I.R.R.M.A.") was signed into law after receiving broad bipartisan support in Congress.
By Nina Krauthamer
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.
By Neha Rastogi, Andreas Apostolides, Stanley Ruchelman
Neglected preferred stock! Yes, this article begins with an oxymoron.
By Galia Antebi
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.
By Stanley Ruchelman
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:
By Galia Antebi, Stanley Ruchelman
Recently, the Court of Appeals for the D.C. Circuit affirmed the 2017 Tax Court ruling in the matter of Grecian Magnesite Mining v. Commr., which held that a foreign corporation was not liable for U.S. tax on the gain ...
By Stanley Ruchelman, Galia Antebi
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.
By Stanley Ruchelman, Galia Antebi
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.
By Stanley Ruchelman, Galia Antebi
As stated in our June 19 Client Alert, the French contribution sociale généralisée and contribution au remboursement de la dette sociale previously were not considered creditable foreign income taxes ...
By Neha Rastogi, Stanley Ruchelman
Imagine a lush green garden on a bright sunny day.
By Galia Antebi, Nina Krauthamer
The clock is ticking for "Opportunity Zones," and the I.R.S. is aware.
By Michael Peggs, Stanley Ruchelman
The limitation of interest deductibility to approximately 30% of E.B.I.T.D.A. (earnings before interest, tax, depreciation, and amortization) introduced in amended Code §163(j) has focused the attention of U.S. corporations ...
By Nina Krauthamer
This article looks into some important tax considerations for an individual planning to start a U.S. business.
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