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1
Have You Inherited A P.F.I.C.? – What It Means To Be A U.S. Beneficiary
In today's global environment, it is not surprising to find that a beneficiary of a foreign estate or trust is living in the U.S.
United States
7 Aug 2018
2
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
3
U.K. Requirement To Correct
The "Requirement to Correct" ("R.T.C.") rules became law when the Finance (No. 2) Act 2017 received Royal Assent on November 16, 2017.
UK
7 Aug 2018
4
A New Tax Regime For CFCS: Who Is GILTI?
When financial analysts of a financial institution review the tax provision of potential customers incident to a financial transaction, the focus typically is directed at current and deferred taxes...
United States
7 Aug 2018
5
I.R.S. Proposed Regulations Provide Clarity On Code §965 Transition Tax
On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code §965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders...
United States
3 Aug 2018
6
A Fundamental Change Of The Professional Sports Landscape Under The 2017 U.S. Tax Reform? The End Of Like-Kind Exchanges For U.S. Sports Trades
The New York Times reported recently that the National Basketball Association ("NBA") and Major League Baseball ("MLB") are reaching out to both Congress and the Trump administration to learn more...
United States
16 Jul 2018
7
Updates And Other Tidbits
In IR-2018-131, issued on June 4, 2018, the I.R.S. announced that it will waive certain late-payment penalties relating to the Code §965 transition tax ...
United States
2 Jul 2018
8
I.R.S. Announces Six Compliance Campaigns
The I.R.S. Large Business and International division ("LB&I") recently announced the approval of the following six additional compliance campaigns:
United States
2 Jul 2018
9
Foreign Investor In A U.S. L.L.C. – How To Minimize Withholding Tax On Sale Of L.L.C. Interest
On April 2, 2018, the I.R.S. published Notice 2018-29 (the "Notice"), describing Treasury Regulations it intends to issue with regard to the new withholding requirement on transfers of partnership interests ...
United States
29 Jun 2018
10
Corporate Matters: Profits Interest Basics
In previous articles we have discussed the relative flexibility of limited liability companies ("L.L.C.'s"), which are generally taxed as partnerships ...
United States
29 Jun 2018
11
The F-1 Visa – Privileged U.S. Tax Status And How To Keep It
Foreign students leaving their home country and arriving in the U.S. for higher education may come across many things that seem alien to them – like the accent, culture, (inexplicably large) food portions, etc.
United States
28 Jun 2018
12
Managing A Transfer Pricing Exam? Wash Your Hands With Soap And Water
The arrival of an information document request ("I.D.R.") for transfer pricing documentation often comes as a surprise to a company.
United States
28 Jun 2018
13
I.R.S. Notice 2018-28 Announces Code §163(J) Regulations On Interest Payment Deductions
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...
United States
18 May 2018
14
A Comparative View Of The Principal Purpose Test – U.S. Tax Court V. B.E.P.S.
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.
United States
16 May 2018
15
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
16
G.D.P.R. Is Imminent – Is Your U.S. Business Prepared?
In Europe, an individual's right to the protection of his or her personal data is a fundamental right.
United States
15 May 2018
17
A New Definition Of Permanent Establishment In Italian Domestic Income Tax Law
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...
Italy
16 Apr 2018
18
Can The Arm's Length Standard Beat The R.A.P.? Transfer Pricing After The T.C.J.A.
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
United States
16 Apr 2018
19
I.R.S. Offers Additional Guidance On Code §965 Transition Tax
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...
United States
16 Apr 2018
20
When "Defective" Is Desirable – Pre-Immigration Planning For Families With U.S. Persons
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...
United States
16 Apr 2018
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