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1
Global Tax Planning In A Pre-2018 World
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:
United States
2 Aug 2019
2
French Social Security Charges (C.S.G. And C .R.D.S.) Are Creditable
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 ...
United States
11 Jul 2019
3
Senate To Vote On Tax Treaties
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.
United States
11 Jul 2019
4
The High-Tax Kickout: G.I.L.T.I. Or Not G.I.L.T.I.?
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.
United States
11 Jul 2019
5
Grecian Magnesite Put To Bed: Tax Court Ruling Affirmed On Appeal
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 ...
United States
11 Jul 2019
6
United States
10 Jul 2019
7
Qualified Opportunity Zones: Second Set Of Proposed Regulations Offers Greater Clarity To Investors
The clock is ticking for "Opportunity Zones," and the I.R.S. is aware.
United States
9 Jul 2019
8
Debt Characterization And Deductibility Under Domesticated International Rules
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 ...
United States
9 Jul 2019
9
The Devil In The Detail: Choosing A U.S. Business Structure Post-Tax Reform
This article looks into some important tax considerations for an individual planning to start a U.S. business.
United States
8 Jul 2019
10
New York State Says No To Annual Pied-À-Terre Tax, Yes To Increased Real Estate Transfer Taxes
New York City's public transportation system is old and in desperate need of significant renovation.
United States
20 Jun 2019
11
Corporate Matters: Delaware Law Allows L.L.C. Divisions
In 2018, Delaware amended its limited liability company act to add Section 18-217, which enables an L.L.C. to divide into two or more newly formed L.L.C.'s, with the dividing company either continuing or terminating its existence.
United States
20 Jun 2019
12
New York State Renews The Three-Year Clawback For Gifts
Generally, Federal estate and gift taxes are imposed on a person's right to transfer property to another person during life or upon death.
United States
20 Jun 2019
13
Missed Opportunities – Tax Court Shows No Mercy For Indirect Partner
At first, it may seem that the I.R.S. was harsh in determining that the taxpayer missed his chance to contest the F.P.A.A. for the two partnerships he held indirectly through another partnership.
United States
19 Jun 2019
14
Peeling The Onion To Allocate Subpart F Income – This Will Make You Cry!
There has been a wealth of conversation addressing the amendment to the definition of a "U.S. Shareholder" in the context of a controlled foreign corporation introduced by the 2017 Tax Cuts and Jobs Act.
United States
18 Jun 2019
15
Proposed F.D.I.I. Regulations: Deductions, Sales, And Services
On December 22, 2017, the Tax Cuts and Jobs Act 2017 ("T.C.J.A.")1 introduced the foreign derived intangible income
United States
18 Jun 2019
16
New Jersey Provides G.I.L.T.I. Guidance
Federal tax law has introduced a new type of gross income. The provisions applicable to Global Intangible Low Tax Income ("G.I.L.T.I.") are designed to stop U.S.
United States
20 May 2019
17
It's Time For Cayman Shell Entities To Come Out Of Their Shells And Show Economic Substance
In response to the O.E.C.D.'s B.E.P.S. recommendations and the conclusions and concerns identified by the E.U. Code of Conduct Group of Business Taxation,
Cayman Islands
20 May 2019
18
State And Local Tax Credit Programs – Businesses May Get What Individuals Cannot
Since recent Federal tax law changes have capped the state and local tax deduction for individuals to $10,000, many states have been trying to implement solutions
United States
20 May 2019
19
The Responsible Party – Changes Effective May 2019
The Federal Taxpayer Identification Number ("T.I.N.") used by entities is the Employer Identification Number ("E.I.N."). The E.I.N. application (both online and using Form SS-4)
United States
20 May 2019
20
Anti-Tax Arbitrage The U.S. Way
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced two new rules targeting hybrid arrangements. The first deals with hybrid dividends.
United States
20 May 2019
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