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By Alev Fanny Karaman
The use of virtual currency is on the rise, and investors and government agencies are taking notice.
By Sheryl Shah, Nina Krauthamer
The I.R.S. announced it will slowly launch a passport denial program with the U.S. State Department beginning in January 2018.
By Rusudan Shervashidze, Nina Krauthamer
A prior article in this series discussed the way U.S. estate tax is imposed on the transfer of artwork at the time of death.
By Alev Fanny Karaman
When non-U.S. entities expand to the U.S., they face several issues, all of them new.
By Beate Erwin, Sheryl Shah
In October, the U.S. District Court for the Western District of Texas struck down a provision under temporary anti-inversion regulations for violating the required notice and comment period...
By Stanley Ruchelman, Elizabeth V. Zanet
In a Code § 351 exchange, the transferee corpora- tion's basis in the contributed IP will be the same as that of the transferor shareholder.
By Elizabeth V. Zanet, Galia Antebi, Stanley Ruchelman
Transactions known as corporate "inversions" or "expatriations" have made headlines for years.
By Neha Rastogi, Michael Peggs
The Action 14 Report introduced a minimum standard on dispute resolution that must be observed by participating countries to ensure that they resolve treaty-re­lated disputes...
By Alev Fanny Karaman, Beate Erwin
The current international tax system was established at a time when the sharing economy did not exist and was not foreseeable.
By Neha Rastogi, Sheryl Shah, Nina Krauthamer
A recent decision, involving Starr International Company ("Starr"), provides insight into what a court may view as relevant in deciding a treaty shopping case.
By Stanley Ruchelman, Neha Rastogi, Sheryl Shah
On October , the "other shoe dropped" on eight regulations issued by the Obama administration in 2016 and January 2017.
By Beate Erwin, Stanley Ruchelman
On August 11, 2017, the O.E.C.D. released comments on the draft 2017 updates to the O.E.C.D. Model Tax Convention prepared by the Committee's Working Party 1 and published on July 11, 2017.
By Elizabeth V. Zanet, Stanley Ruchelman
Arrangements to shift formal voting power away from U.S. shareholders are not giv¬en effect if voting power is retained in reality.
By Rusudan Shervashidze, Nina Krauthamer
The painting you bought when you were a student may worth something today. Or maybe you have accumulated a collection of artwork that has a significant value.
By Beate Erwin, Alev Fanny Karaman
The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.