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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, Elizabeth V. Zanet, 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").
By Elizabeth V. Zanet, Rusudan Shervashidze, Beate Erwin
The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").
By Galia Antebi, Nina Krauthamer, Alev Fanny Karaman
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code §199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
The new limitation on the deduction will increase the cost of owning a home, which will in turn depress home values.
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
Colombian singer Shakira, was also ordered to pay more than €20 million in back taxes to Spain
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
On September 19, 2018, the European Commission issued a decision that nontaxation of certain McDonald's profits in Luxembourg was not illegal State Aid.
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
Mr. Baron was extradited to the U.S. from Hungary in July.
By Michael Peggs, Scott R. Robson
The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.
By Elizabeth V. Zanet, Stanley Ruchelman
The U.S. person must prepare a valuation of the intangible property in accordance with rules set forth in the Treasury regulations.
By Rusudan Shervashidze, Nina Krauthamer
A participating F.F.I. files Form 8966, F.A.T.C.A. Report, annually with the I.R.S. The
By Galia Antebi, Nina Krauthamer
The U.S. Federal, state, and local governments typically offer tax benefits to businesses to encourage economic growth and investment in certain industries and geographic areas.
By Alev Fanny Karaman, Beate Erwin
This article focuses on the interaction between certain hybrid mismatch provisions of A.T.A.D. 2 and certain provisions of U.S. tax law.
By Elizabeth V. Zanet, Stanley Ruchelman
Like most assets developed, used, and sold in business, intellectual property (IP) is subject to important tax considerations.