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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:
By Galia Antebi, Stanley Ruchelman
Recently, the Court of Appeals for the D.C. Circuit affirmed the 2017 Tax Court ruling in the matter of Grecian Magnesite Mining v. Commr., which held that a foreign corporation was not liable for U.S. tax on the gain ...
By Stanley Ruchelman, Galia Antebi
On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.
By Stanley Ruchelman, Galia Antebi
On June 25, the Senate Foreign Relations Committee approved protocols to four income tax treaties, clearing the way for the treaties to be considered by the full Senate.
By Stanley Ruchelman, Galia Antebi
As stated in our June 19 Client Alert, the French contribution sociale généralisée and contribution au remboursement de la dette sociale previously were not considered creditable foreign income taxes ...
By Neha Rastogi, Stanley Ruchelman
Imagine a lush green garden on a bright sunny day.
By Galia Antebi, Nina Krauthamer
The clock is ticking for "Opportunity Zones," and the I.R.S. is aware.
By Michael Peggs, Stanley Ruchelman
The limitation of interest deductibility to approximately 30% of E.B.I.T.D.A. (earnings before interest, tax, depreciation, and amortization) introduced in amended Code §163(j) has focused the attention of U.S. corporations ...
By Nina Krauthamer
This article looks into some important tax considerations for an individual planning to start a U.S. business.
By Nina Krauthamer
New York City's public transportation system is old and in desperate need of significant renovation.
By Simon H. Prisk
In 2018, Delaware amended its limited liability company act to add Section 18-217, which enables an L.L.C. to divide into two or more newly formed L.L.C.'s, with the dividing company either continuing or terminating its existence.
By Nina Krauthamer
Generally, Federal estate and gift taxes are imposed on a person's right to transfer property to another person during life or upon death.
By Nina Krauthamer
At first, it may seem that the I.R.S. was harsh in determining that the taxpayer missed his chance to contest the F.P.A.A. for the two partnerships he held indirectly through another partnership.
By Stanley Ruchelman, Neha Rastogi
There has been a wealth of conversation addressing the amendment to the definition of a "U.S. Shareholder" in the context of a controlled foreign corporation introduced by the 2017 Tax Cuts and Jobs Act.
By Beate Erwin
On December 22, 2017, the Tax Cuts and Jobs Act 2017 ("T.C.J.A.")1 introduced the foreign derived intangible income
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