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By Astrid Champion, Nina Krauthamer
On March 3, 2017, the U.S. Court of Federal Claims ruled that a taxpayer's liability for the domicile levy in Ireland does not qualify him as a resident of the country under the U.S.-Ireland Income Tax Treaty.
By Michael Peggs
In finding for the taxpayer in a recent transfer pricing decision, the U.S. Tax Court followed its own determination in Veritas in valuing a buy-in payment made as compensation...
By Philip Hirschfeld
Every cloud has a silver lining. This expression also applies to the world of tax. Troubled companies that incur significant operational and interest expenses may find that they have generated...
By Elizabeth V. Zanet, Stanley Ruchelman
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...
By Galia Antebi, Kenneth Lobo
The U.S. applies a worldwide tax system imposed on residents and citizens alike.
By Rusudan Shervashidze, Stanley Ruchelman
In early April, Bloomberg News reported on coordinated tax raids on three separate offices of Credit Suisse.
By Alev Fanny Karaman, Galia Antebi
The foreign tax credit ("F.T.C.") is a keystone of U.S. outbound tax legislation.
By Alev Fanny Karaman, Beate Erwin, Stanley Ruchelman
As explained in an earlier article,1 a common civil law estate planning technique involves an older generation making a gift of bare ownership in an income generating asset to members of a younger generation.
By Alev Fanny Karaman, Stanley Ruchelman
Splitting ownership into usufruct and bare ownership is a common estate planning technique in several civil law countries.
By Alev Fanny Karaman
While a French-U.S. perspective is reflected in this article, most foreign tax lawyers practicing in the U.S. may find part of their own experience mirrored here.
By Philip Hirschfeld, Kenneth Lobo
The House plan to tax imports and exempt exports is part of a tax reform package that is expected to raise more than $1 trillion to offset lower income tax rates and improve U.S. competitiveness against global rivals.
By Stanley Ruchelman, Galia Antebi
The I.P.U. acknowledges that exceptions are provided for small corporations and transactions of de minimis value.
By Rusudan Shervashidze, Philip Hirschfeld
The Internal Revenue Code (the "Code") provides a foreign earned income and housing cost exclusion to qualified individuals, subject to some limitations set out in Code §911(b)(2).
By Philip Hirschfeld
In a 21st century America where new ideas continually create new intangible property, U.S. corporations often desire to contribute their I.P. to a foreign affiliate who then develops and...
By Kenneth Lobo, Beate Erwin
Using deductible interest payments to reduce U.S. taxable income is often a goal of tax practitioners.