Mondaq USA: Tax > Withholding Tax
Cadwalader, Wickersham & Taft LLP
Private debt funds raised more than $100 billion for the fourth consecutive year in 2018,[1] and reached their highest level of fundraising on record during the first half of 2019.[2]
Morrison & Foerster LLP
Gone are the days that employees work from only one location from 9:00 a.m. to 5:00 p.m. With employees traveling throughout the U.S., and in many instances
Ruchelman PLLC
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.
Morrison & Foerster LLP
Gone are the days that employees work from only one location from 9:00 a.m. to 5:00 p.m. With employees traveling throughout the U.S.
Withers LLP
Several recent rulings concerning the tax exemption applicable to institutional investors into Italian real estate investment funds ("*REIFs*")
Morrison & Foerster LLP
After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new apportionment rules
Seyfarth Shaw LLP
On August 14, 2019, the IRS issued Revenue Ruling 2019-19, providing guidance to both tax-qualified plan administrators and participants on the tax treatment of plan distribution checks
Ruchelman PLLC
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:
Ruchelman PLLC
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 ...
Eide Bailly LLP
The Tax Cuts and Jobs Act brought about many changes for multinational businesses. One of the more significant changes was the application of Global Intangible Low-Taxed Income to foreign subsidiaries.
Arnold & Porter
On June 6, 2019 the US Internal Revenue Service and US Department of the Treasury issued proposed regulations that provide guidance with respect to (1) the scope of the exception for a "qualified foreign pension fund" ...
Kirkland & Ellis International LLP
On May 7, 2019, the Internal Revenue Service ("IRS") issued proposed regulations under the 2017 Tax Cuts and Jobs Act1 ("TCJA")
Hogan Lovells
Proposed regulations have recently been issued by the U.S. Internal Revenue Services (IRS) under a withholding provision of U.S. tax law
Proskauer Rose LLP
On May 13, 2019, the IRS and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests ...
Dentons
The Treasury Department and IRS invite taxpayers to submit comments on the proposed regulations on or before May 6, 2019.
Ruchelman PLLC
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced two new rules targeting hybrid arrangements. The first deals with hybrid dividends.
Withers LLP
American donors may qualify for a US charitable estate tax deduction even if assets are left to a non-US charity provided that the charity has purposes which are charitable in the US
Ruchelman PLLC
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 ...
Withers LLP
The protocol amending the United States Tax Treaty with Switzerland has been ratified by the United States and began to take effect as of 20 September 2019.
Duff and Phelps
The last two decades have witnessed a substantial growth in debt funds.
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Morrison & Foerster LLP
Gone are the days that employees work from only one location from 9:00 a.m. to 5:00 p.m. With employees traveling throughout the U.S.
Withers LLP
Several recent rulings concerning the tax exemption applicable to institutional investors into Italian real estate investment funds ("*REIFs*")
Ruchelman PLLC
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.
Withers LLP
The protocol amending the United States Tax Treaty with Switzerland has been ratified by the United States and began to take effect as of 20 September 2019.
Cadwalader, Wickersham & Taft LLP
Private debt funds raised more than $100 billion for the fourth consecutive year in 2018,[1] and reached their highest level of fundraising on record during the first half of 2019.[2]
Morrison & Foerster LLP
Gone are the days that employees work from only one location from 9:00 a.m. to 5:00 p.m. With employees traveling throughout the U.S., and in many instances
Dentons
The Treasury Department and IRS invite taxpayers to submit comments on the proposed regulations on or before May 6, 2019.
Ruchelman PLLC
The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").
Morrison & Foerster LLP
After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new apportionment rules
Ruchelman PLLC
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.
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