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Tax Treaties
United States
O'Sullivan Estate Lawyers LLP
There is increasing uncertainty about the future of U.S. estate tax. On the one hand, under U.S. legislation that temporarily halved the lifetime exemption amount passed...
Crowell & Moring LLP
On December 19, 2023, the bilateral income tax treaty between the United States and Chile (formally, the Convention between the Government of the United States of America and the Government...
A study on tax-related measures in investor-State arbitration, co-authored with Professor Yarik Kyrvoi, Senior Fellow in International Economic Law and Director of the Investment Treaty Forum at the British Institute of International and Comparative Law.
Caplin & Drysdale
Countries agreed to push back a deadline to sign a multilateral treaty that's part of the international tax pact until mid-2024...
Ruchelman PLLC
The reliance on smartphone G.P.S. applications is nearly ubiquitous in today's world. These "map apps" not only furnish diverse routes to destinations...
Lowenstein Sandler
Unlike most countries in the world, if you are a citizen or resident of the United States, the government gets to tax all of your worldwide income, regardless of where it's earned or where you live.
Miller & Chevalier Chartered
While the Speaker drama unfolds and we find ourselves in the middle of the third week of a paralyzed House, Tax Take turns its attention to some noteworthy international tax developments.
Miller & Chevalier Chartered
The anticipated government shutdown was avoided by the surprise bipartisan continuing resolution (CR), the Continuing Appropriations Act, 2024 and Other Extensions Act...
Cadwalader, Wickersham & Taft LLP
GE Financial Investments Limited ("GEFI Limited") was a UK incorporated and tax resident company and a member of the General Electric group.
Pillsbury Winthrop Shaw Pittman
On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey's Corporation Business Tax ("CBT"). The bill enacted a variety of clarifications, corrections, and modifications to the CBT.
Proskauer Rose LLP
If the bill is passed, it would deny the benefits of section 892 to several of the largest sovereign wealth funds by assets.
Caplin & Drysdale
One key component of the OECD's Pillar One proposal to reallocate taxing rights from producer to consumer nations is the promise that businesses and governments...
Withers LLP
Many people come to California temporarily for work from outside the US and then end up becoming part of the great economy that encourages innovation and entrepreneurship for the long haul.
Kramer Levin Naftalis & Frankel LLP
On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive...
Shearman & Sterling LLP
On December 19, 2023, the U.S. Treasury Department ("Treasury") announced the entry into force of the U.S.-Chile Income Tax Treaty (the "Treaty").
Gray Reed & McGraw LLP
In recent years the IRS has become aware that U.S. taxpayers are participating in transactions known as "Malta pension plans" (Malta plans). Typically, in these transactions, a U.S...
Ruchelman PLLC
A robust and extensive income tax treaty network has worked to the advantage of U.S. corporations and individuals.
Ruchelman PLLC
If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.
Kramer Levin Naftalis & Frankel LLP
On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty)...
Miller & Chevalier Chartered
The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.
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