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Searching Content indexed under Tax Authorities by Ruchelman PLLC ordered by Published Date Descending.
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1
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
2
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
3
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
4
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
5
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
6
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
7
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
8
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
9
Who's Got The B.E.A.T.? Special Treatment For Certain Expenses And Industries
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities ...
United States
12 Apr 2019
10
Democrats Turn To Tax Reform To Reduce Wealth Disparity
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 ...
United States
12 Apr 2019
11
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
12
Can Tax Authorities Demand Access To Audit Workpapers? Canadian Experience Follows U.S. Rule
When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure...
United States
8 Mar 2019
13
Changes In China's Tax Law Affect Foreign Nationals
As of last September, China has begun sharing taxpayer financial information of residents and nonresidents with over 100 countries under the Common Reporting System ("C.R.S.").
China
5 Feb 2019
14
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
15
A Deep Dive Into G.I.L.T.I. Guidance
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").
United States
12 Dec 2018
16
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
17
New York And Neighboring States Bring Action Against The Federal Government
The new limitation on the deduction will increase the cost of owning a home, which will in turn depress home values.
United States
18 Oct 2018
18
D.O.J. Resorts To Undercover Operations To Secure First Conviction Under F. A.T.C.A.
Mr. Baron was extradited to the U.S. from Hungary in July.
United States
18 Oct 2018
19
O.E.C.D. Discussion Draft On Financial Transactions – A Listing Of Sins, Little Practical Guidance
The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.
United States
18 Oct 2018
20
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
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