Searching Content indexed under Tax Treaties by Ruchelman PLLC ordered by Published Date Descending.
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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
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
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
More Permanent Establishments: The Dwindling Preparatory And Auxiliary Activities Exception
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
United States
11 Apr 2019
The I.R.S. Approach To Dependent Agent Status
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.
United States
11 Apr 2019
Who's Got The B.E.A.T.? A Playbook For Determining Applicable Taxpayers And Payments
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
United States
11 Mar 2019
Proposed Code §864(C)(8) Regulations Codify Tax On Gain From Sale Of Partnership Interest
Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").
United States
8 Mar 2019
Mirror, Mirror, On The Wall, Which Is My Tax Home Of Them All? – Foreign Students Face Dilemma In The U.S.
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
United States
5 Feb 2019
Holding Companies Of Europe – Tax Planning For European Expansion In A Changing Landscape
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 ...
United States
15 Jan 2019
How To Handle Dual Residents: The I.R.S. View On Treaty Tie-Breaker Rules
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 ...
United States
12 Dec 2018
I.R.S. Announces Six Compliance Campaigns
The I.R.S. Large Business and International division ("LB&I") recently announced the approval of the following six additional compliance campaigns:
United States
2 Jul 2018
Tax Cuts And Jobs Act Adopt Provisions To Prevent Base Erosion
Following the lead of the O.E.C.D. and the European Commission ("E.C."), the Tax Cuts and Jobs Act ("T.C.J.A.") adopts several provisions designed to end certain tax planning opportunities.
United States
5 Feb 2018
Updates & Other Tidbits – Insights Volume 4 Number 10
A recent decision, involving Starr International Company ("Starr"), provides insight into what a court may view as relevant in deciding a treaty shopping case.
23 Nov 2017
O.E.C.D. Receives Public Comments On Proposed Changes To The Model Tax Convention
On August 11, 2017, the O.E.C.D. released comments on the draft 2017 updates to the O.E.C.D. Model Tax Convention prepared by the Committee's Working Party 1 and published on July 11, 2017.
United States
21 Nov 2017
The Sharing Economy Part 1:New Business Models +Traditional Tax Rules Don't Mix
The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.
United States
17 Nov 2017
The Changing Face Of Service Permanent Establishments
The Johannesburg Tax Court reached a similar conclusion, albeit along a different path, in a case that addressed a matter involving a U.S. service provider.
United States
16 Nov 2017
O.E.C.D. Issues Proposed Changes To Permanent Establishment Provisions Under Model Tax Convention
On July 11, 2017, the O.E.C.D. Committee on Fiscal Affairs released the draft contents of the 2017 update to the O.E.C.D. Model Tax Convention and the Commentary prepared by the Committee's Working Party 1.
United States
4 Oct 2017
Bilateral Investment Treaties: When Double Taxation Agreements Are Not Enough
The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.
United States
3 Oct 2017
European Parliament Extends Scope Of Country-By-Country Reporting
With the objective of enhancing transparency and public scrutiny on corporate income tax, the European Commission adopted a proposal.
European Union
4 Sep 2017
Outbound Acquisitions:Holding Companies Of Europe – A Guide For Tax Planning, Or A Road Map For Difficulty?
When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.
United States
23 Aug 2017
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