Searching Content by Galia Antebi ordered by Published Date Descending.
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French Social Security Charges (C.S.G. And C .R.D.S.) Are Creditable
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 ...
United States
11 Jul 2019
Senate To Vote On Tax Treaties
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.
United States
11 Jul 2019
The High-Tax Kickout: G.I.L.T.I. Or Not G.I.L.T.I.?
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.
United States
11 Jul 2019
Grecian Magnesite Put To Bed: Tax Court Ruling Affirmed On Appeal
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 ...
United States
11 Jul 2019
Qualified Opportunity Zones: Second Set Of Proposed Regulations Offers Greater Clarity To Investors
The clock is ticking for "Opportunity Zones," and the I.R.S. is aware.
United States
9 Jul 2019
It's Time For Cayman Shell Entities To Come Out Of Their Shells And Show Economic Substance
In response to the O.E.C.D.'s B.E.P.S. recommendations and the conclusions and concerns identified by the E.U. Code of Conduct Group of Business Taxation,
Cayman Islands
20 May 2019
The Responsible Party – Changes Effective May 2019
The Federal Taxpayer Identification Number ("T.I.N.") used by entities is the Employer Identification Number ("E.I.N."). The E.I.N. application (both online and using Form SS-4)
United States
20 May 2019
Proposed Amendments To F.A.T.C.A. Suggest Reducing Or Deferring Withholding
On December 13, 2018, the I.R.S. issued proposed regulations under Code §§1471 through 1474 (F.A.T.C.A provisions) as well as under Code §§1441 and 1461 (withholding on non-U.S.
United States
11 Mar 2019
Qualified Business Income – Are You Eligible For A 20% Deduction? Part II: Additional Guidance
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code §199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
United States
12 Nov 2018
The Opportunity Zone Tax Benefit – How Does It Work And Can Foreign Investors Benefit?
The U.S. Federal, state, and local governments typically offer tax benefits to businesses to encourage economic growth and investment in certain industries and geographic areas.
United States
18 Oct 2018
Blockchain 101
Blockchain has recently been in the spotlight, mostly due to the 2017 surge in cryptocurrency values and the rise of initial coin offerings ("I.C.O.'s").
United States
7 Aug 2018
Code §962 Election Offers Benefits Under U.S. Tax Reform
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.
United States
16 May 2018
Investing In U.S. Real Estate On A (Possibly) Tax-Free Basis
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.
United States
13 Apr 2018
B.E.A.T.-Ing Base Erosion: U.S. Subjects Large Corporations To Anti-Abuse Tax
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 ...
United States
9 Mar 2018
Anti-Inversion Rules Are Not Just For Mega-Mergers – Private Client Advisors Take Note
Transactions known as corporate "inversions" or "expatriations" have made headlines for years.
United States
7 Dec 2017
Family Limited Partnerships In Estate Planning - Is Estate Of Powell The End Or The Beginning Of Aggressive Tax Planning?
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...
United States
24 Aug 2017
I.R.S. Pushes To Ease Implementation Of Country-By-Country Reporting For U.S. M.N.E.'S
While the U.S. still refuses to sign onto the O.E.C.D.'s Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the "CbC M.C.A.A."), the I.R.S. is making progress...
United States
17 Jul 2017
Foreign Tax Credit May Not Be Available For Gains Derived Outside The U.S.
The U.S. applies a worldwide tax system imposed on residents and citizens alike.
United States
2 Jun 2017
Foreign Tax Credits: General Principles And Audit Risks
The foreign tax credit ("F.T.C.") is a keystone of U.S. outbound tax legislation.
United States
31 May 2017
LB&I Audit Insights: Using A Code §6038A Summons When A U.S. Corporation Is 25% Foreign Owned
The I.P.U. acknowledges that exceptions are provided for small corporations and transactions of de minimis value.
United States
11 May 2017
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