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By Stanley Ruchelman, Rusudan Shervashidze
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities ...
By Nina Krauthamer
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 ...
By Neha Rastogi, Beate Erwin
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
By Beate Erwin, Alev Fanny Karaman
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
By Nina Krauthamer, Rusudan Shervashidze
April 15 is almost here, and while most people know this date as the filing deadline for individual tax returns, it also important to another filing requirement:
By Stanley Ruchelman, Rusudan Shervashidze
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax
By Galia Antebi
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.
By Alev Fanny Karaman, Nina Krauthamer
Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").
By Stanley Ruchelman
When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure...
By Stanley Ruchelman, Rusudan Shervashidze
As of last September, China has begun sharing taxpayer financial information of residents and nonresidents with over 100 countries under the Common Reporting System ("C.R.S.").
By Neha Rastogi, Beate Erwin
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
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: (i) the reduction of European taxes ...
By Alev Fanny Karaman, Beate Erwin
The first step in advising a foreign individual who is neither a U.S. citizen nor a green card holder on U.S. income tax laws is to determine the person's residence ...
By Stanley Ruchelman
On October 31, 2018, the I.R.S. proposed regulations affecting controlled foreign corporations ("C.F.C.'s") and U.S. corporations that are considered to be U.S. Shareholders ...
By Stanley Ruchelman, Rusudan Shervashidze
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced a new anti-abuse tax regime applicable to controlled foreign corporations ("C.F.C.'s").
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