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By Simon H. Prisk
Commencing in January 2018, the I.R.S. began a new centralized audit regime with respect to partnerships. It replaces the concept of a "Tax Matters Partner" with a "Partnership Representative.
By Rusudan Shervashidze, Stanley Ruchelman
Changes to U.S. tax law brought about by the 2017 Tax Cuts and Job Act ("T.C.J.A.") have affected many longstanding tax planning tools.
By Sheryl Shah
The Tax Cuts and Jobs Act ("T.C.J.A.") brought many changes for non-corporate taxation, changing tax rates and repealing many popular deductions.
By Galia Antebi, Sheryl Shah
The Tax Cuts and Jobs Act ("T.C.J.A.") introduced Code §59A, which imposes a new Base Erosion and Anti-Abuse Tax ("B.E.A.T.") on large corporations that significantly reduce their U.S. tax liability ...
By Alev Fanny Karaman, Stanley Ruchelman
The Tax Cuts and Jobs Act ("T.C.J.A."), signed into law on December 22, 2017, contained several major changes with respect to individuals and entities.
By Neha Rastogi, Nina Krauthamer
Companies and financial institutions are not liable for inheritance tax and therefore do not face additional tax.
By Neha Rastogi, Nina Krauthamer
They do not apply the B.E.P.S. minimum standards, nor have they committed to address these issues by the E.U. deadline, December 31, 2018.
By Neha Rastogi, Nina Krauthamer
Federal returns that are submitted in 2018 with an expired I.T.I.N. will be processed.
By Stanley Ruchelman
The Large Business and International Division of the I.R.S. ("LB&I") periodically develops international practice units ("I.P.U.'s") that serve as training material ...
By Alev Fanny Karaman, Nina Krauthamer
As explained in the January 2017 edition of Insights, the end of the year in France is always marked by a fiscal legislative process to amend the current year's finance law ...
By Sheryl Shah, Stanley Ruchelman
Following the lead of the O.E.C.D. and the European Commission ("E.C."), the Tax Cuts and Jobs Act ("T.C.J.A.") adopts several provisions designed to end certain tax planning opportunities.
By Neha Rastogi, Stanley Ruchelman
One of the principal revisions to U.S. tax law made by the TCJA involves the way U.S. tax law avoids double taxation when a foreign subsidiary distributes a dividend to a U.S. corporation...
By Elizabeth V. Zanet, Stanley Ruchelman
The 2017 Tax Cuts and Jobs Act introduces a new tax regime applicable to con¬trolled foreign corporations ("C.F.C.'s").
By Rusudan Shervashidze, Stanley Ruchelman
This article addresses provisions of the Tax Cuts and Jobs Act of 2017 that affect certain U.S. investors in foreign corporations on a go-forward basis and a one-year transition period for the 2017 taxable year.
By Alev Fanny Karaman
The use of virtual currency is on the rise, and investors and government agencies are taking notice.