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By Rusudan Shervashidze, Nina Krauthamer
The I.R.S. has announced that it disagrees with the ruling in Bartell v. Commr.1 in an Action on Decision ("A.O.D.") issued on August 14, 2017, expressing its "nonacquiescence" with the case.
By Michael Peggs
As the transfer pricing travails of Eaton Corporation ("Eaton") continue, a recent U.S. Tax Court decision affirmed that (i) I.R.S. administrative rules set down in rev¬enue procedures...
By Neha Rastogi, Beate Erwin, Stanley Ruchelman
On July 11, 2017, the O.E.C.D. Committee on Fiscal Affairs released the draft contents of the 2017 update to the O.E.C.D. Model Tax Convention and the Commentary prepared by the Committee's Working Party 1.
By Rusudan Shervashidze, Nina Krauthamer
The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.
By Elizabeth V. Zanet, Stanley Ruchelman
For many years, the U.S. government has been concerned about U.S. businesses reducing or deferring U.S. income tax liabilities through the use of foreign corporations.
By Neha Rastogi, Alev Fanny Karaman, Stanley Ruchelman
Major corporate transactions typically reflect at least two separate elements.
By Beate Erwin, Stanley Ruchelman
Five-time Super Bowl champions the New England Patriots have earned a new title: the first team in NFL history to buy their own fleet of planes.
By Neha Rastogi, Nina Krauthamer
On April 21, 2017, President Trump issued Executive Order 13789 (the "Order") with the objective of identifying and reducing tax regulatory burdens imposed by Treasury Regulations (the "Regulations").
By Neha Rastogi, Nina Krauthamer
With the objective of enhancing transparency and public scrutiny on corporate income tax, the European Commission adopted a proposal.
By Neha Rastogi, Stanley Ruchelman
While determining whether a taxpayer has complied with its obligation to provide the I.R.S. with information on its international operations as required by Code §6038 for outbound transactions and by Code §6038A...
By Rusudan Shervashidze
You may have heard the warnings before: Each tax season, the I.R.S. issues guid¬ance urging taxpayers to watch out for new and evolving phishing schemes intend¬ed, in one way or another...
By William Hancock, Daniel Simon
In Sweden, it is traditional on Thursdays to lunch on a split pea soup followed by pancakes, jam, and cream.
By Neha Rastogi, Elizabeth V. Zanet, Nina Krauthamer
In Grecian Magnesite Mining, Industrial & Shipping Co., S.A. v. Commr.,1 the U.S. Tax Court recently held that a foreign partner was not subject to U.S. Federal tax when it redeemed its interest in a U.S. partnership...
By Elizabeth V. Zanet, Stanley Ruchelman
This article will review the basic U.S. Federal tax considerations of intellectual prop¬erty ("I.P.") taxation in the context of corporations and partnerships and examine some typical tax considerations...
By Rusudan Shervashidze, Galia Antebi
Instead of following the standard I.R.S. approach1 for cases where Code §2036(a) was applied, which was never contested, the court adopted a new, untested theory– one that could potentially create...