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I.R.S. Placing Watchdog Agents In International Financial Centers
Over the past few years, global financial regulators and treasury departments have continuously sought out new ways to expose individuals engaged in cryptocurrency transactions.
United States
5 Dec 2019
S.A.L.T. Cap Repeal Case Dismissed
Married individuals filing separately are capped at $5,000.
United States
4 Dec 2019
Saving Clementine: Improving The Code §163(J) Deduction
Oh my darling, oh my darling, oh my darling, Clementine, You are lost and gone forever, dreadful sorrow, Clementine.
United States
3 Dec 2019
Nonprofits: Creeping Commercialization And The Specter Of Unrelated Business Income Tax
In 2018, charitable giving in the U.S. totaled over $427 billion. Of that amount, 68% of that giving came from individuals, 18% from foundations, 9% from bequests, and 5% from corporations, according to Giving USA.
United States
2 Dec 2019
Domestic Partnerships Treated As Entities And Aggregates: New Approach For G.I.L.T.I. And Subpart F
The effect of the T.C.J.A. continues to be encountered in unexpected ways during the second year after its enactment.
United States
29 Nov 2019
Collecting Another Country's Taxes – Recent Experience In The Canada-U.S. Context
When asking a U.S. tax adviser to describe the "revenue rule," it would not be surprising for the adviser to say that it refers to formal guidance issued by the I.R.S. that can be relied on by other taxpayers as authority for a position taken in a tax return.
United States
28 Nov 2019
How Soon Is Now? O.E.C.D. Starts Work On A Substitute For Unilateral Digital Economy Fixes
This month finds the arm's length principle continuing to operate among O.E.C.D. Member States and the broader inclusive framework working toward international tax reform of the digitized economy.
United States
26 Nov 2019
Cryptocurrencies - Latest Developments On Either Side Of The Atlantic And Beyond
What is needed is an electronic payment system based on cryptographic proof instead of trust, allowing any two willing parties to transact directly with each other without the need for a trusted third
United States
11 Oct 2019
U.S. Taxation Of Cloud Transactions And Digital Content Transfers: 20-Year-Old Regulations Finally Move With The Times
To put things in perspective, when the -18 Regulations were adopted, a typical internet connection could download 1GB in approximately 48 hours.
United States
10 Oct 2019
F.I.R.R.M.A. Proposed Regulations Expand C.F.I.U.S. Oversite On Foreign Investment
On August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 ("F.I.R.R.M.A.") was signed into law after receiving broad bipartisan support in Congress.
United States
8 Oct 2019
U.S. Tax Litigation Update — The President's Tax Returns And The New S.A.L.T. Cap
The political battle between the Democrats in the House of Representatives and President Trump concerning the release of tax returns has moved to the courts.
United States
7 Oct 2019
United States
4 Oct 2019
Do You Have To Withhold 30% On Payments To A Non-U.S. Independent Contractor?
In connection with income from the performance of services, non-U.S. individuals are subject to U.S. tax only on U.S.-source income.
United States
3 Oct 2019
Global Tax Planning In A Pre-2018 World
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations:
United States
2 Aug 2019
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
United States
10 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
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