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By Elizabeth V. Zanet, Beate Erwin
The I.R.S. recently issued Notice 2018-28, announcing that it intends to release regulations on various issues pertaining to the limitation on the deductibility of certain interest payments...
By Rusudan Shervashidze, Stanley Ruchelman
In the procedural maze that leads to a trial in the U.S. Tax Court, motion practice is an important part of tailoring issues presented to the court.
By Elizabeth V. Zanet, Galia Antebi
Under Code §962, an individual U.S. Shareholder may elect to be treated as a domestic C-corporation for the purpose of computing income tax on its share of Subpart F Income.
By Alev Fanny Karaman, Beate Erwin
In Europe, an individual's right to the protection of his or her personal data is a fundamental right.
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.