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Ruchelman PLLC
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Tel: +1 212 755.3333
Fax: +1 212 755.5898
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New York
NY 10155
United States
By Ruchelman PLLC
Effective January 1, 2018, Italy's 2018 Budget Law significantly amended the domestic definition of permanent establishment and implemented certain O.E.C.D. guidelines set forth under B.E.P.S. Action 1...
By Michael Peggs, Sheryl Shah
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
By Rusudan Shervashidze, Stanley Ruchelman
On the way toward a dividends received deduction for certain dividends paid by foreign subsidiaries, Congress enacted a one-shot income inclusion of all post-1986 earnings...
By Alev Fanny Karaman, Nina Krauthamer
When it comes to pre-immigration planning, there are greater opportunities when the individual moving to the U.S. is not yet a U.S. person for U.S. tax purposes: Various techniques are available...
By Galia Antebi, Neha Rastogi
Real Estate Investment Trust ("R.E.I.T.") is an entity that generally owns and typically operates a pool of income-producing real estate properties, including mortgages.
By Neha Rastogi, Sheryl Shah, Elizabeth V. Zanet, Beate Erwin
One of the principal revisions to U.S. tax law made by the Tax Cuts and Jobs Act ("T.C.J.A.") was a series of changes to the definition of the term Controlled Foreign Corporation ("C.F.C.").
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 ...