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Tel: +1 212 755.3333
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NY 10155
United States
By Stanley Ruchelman, Rusudan Shervashidze
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
By Galia Antebi
On December 13, 2018, the I.R.S. issued proposed regulations under Code §§1471 through 1474 (F.A.T.C.A provisions) as well as under Code §§1441 and 1461 (withholding on non-U.S.
By Alev Fanny Karaman, Nina Krauthamer
Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").
By Stanley Ruchelman
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...
By Stanley Ruchelman, Rusudan Shervashidze
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.").
By Neha Rastogi, Beate Erwin
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
By Stanley Ruchelman
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 ...
By Alev Fanny Karaman, Beate Erwin
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 ...
By Stanley Ruchelman
On October 31, 2018, the I.R.S. proposed regulations affecting controlled foreign corporations ("C.F.C.'s") and U.S. corporations that are considered to be U.S. Shareholders ...
By Stanley Ruchelman, Rusudan Shervashidze
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").
By Ruchelman PLLC, Rusudan Shervashidze, Beate Erwin
The Treasury Department and the I.R.S. recently published proposed regulations on Code §965 (the "Proposed Regulations").
By Galia Antebi, Nina Krauthamer, Alev Fanny Karaman
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code §199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
The new limitation on the deduction will increase the cost of owning a home, which will in turn depress home values.
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
Colombian singer Shakira, was also ordered to pay more than €20 million in back taxes to Spain
By Rusudan Shervashidze, Neha Rastogi, Nina Krauthamer
On September 19, 2018, the European Commission issued a decision that nontaxation of certain McDonald's profits in Luxembourg was not illegal State Aid.