Searching Content indexed under Capital Gains Tax by Ruchelman PLLC ordered by Published Date Descending.
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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
United States
10 Jul 2019
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
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
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
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
Transition Tax – Proposed Regulations Are Here
The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").
United States
12 Nov 2018
The Opportunity Zone Tax Benefit – How Does It Work And Can Foreign Investors Benefit?
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.
United States
18 Oct 2018
U.K. Requirement To Correct
The "Requirement to Correct" ("R.T.C.") rules became law when the Finance (No. 2) Act 2017 received Royal Assent on November 16, 2017.
7 Aug 2018
Corporate Matters: Profits Interest Basics
In previous articles we have discussed the relative flexibility of limited liability companies ("L.L.C.'s"), which are generally taxed as partnerships ...
United States
29 Jun 2018
Investing In U.S. Real Estate On A (Possibly) Tax-Free Basis
Real Estate Investment Trust ("R.E.I.T.") is an entity that generally owns and typically operates a pool of income-producing real estate properties, including mortgages.
United States
13 Apr 2018
Art And The Estate: Why Planning Is Important, Part I – U.S. Taxpayers
The painting you bought when you were a student may worth something today. Or maybe you have accumulated a collection of artwork that has a significant value.
United States
20 Nov 2017
The Economic Substance Doctrine: A U.S. Anti-Abuse Rule
Major corporate transactions typically reflect at least two separate elements.
United States
29 Sep 2017
Foreign Partner Not Subject To U.S. Tax On Gain From Redemption Of U.S. Partnership Interest
In Grecian Magnesite Mining, Industrial & Shipping Co., S.A. v. Commr.,1 the U.S. Tax Court recently held that a foreign partner was not subject to U.S. Federal tax when it redeemed its interest in a U.S. partnership...
United States
30 Aug 2017
Taxation Of Intellectual Property – Selected Tax Issues Involving Corporations And Partnerships
This article will review the basic U.S. Federal tax considerations of intellectual prop¬erty ("I.P.") taxation in the context of corporations and partnerships and examine some typical tax considerations...
United States
25 Aug 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
Sale Of An Interest By A Foreign Partner – Is Rev. Rul. 91-32 Based On Law Or Administrative Wishes?
In Rev. Rul. 91-32, the I.R.S. announced its view that foreign partners in partnerships operating in the U.S. are properly taxed on their capital gains under a look-thru rule to the assets owned by...
United States
14 Jul 2017
Qualified Small Business Stock & The Eb-5 Visa Program – An Attractive Combination For Potential Investors
In today's start-up world, angel investing1 is a typical part of an entrepreneur's rou¬tine.
United States
13 Jul 2017
Taxation Of Intellectual Property – The Basics
Change driven by development of intellectual property ("I.P.") is now a constant. Whether the I.P. user is a tax adviser accessing a digital library, an auto mechanic interfacing with an engine...
United States
12 Jun 2017
Foreign Tax Credit May Not Be Available For Gains Derived Outside The U.S.
The U.S. applies a worldwide tax system imposed on residents and citizens alike.
United States
2 Jun 2017
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