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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
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
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
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
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...
16 Apr 2018
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
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
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
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
Changes To C.F.C. Rules – More C.F.C.'s, More U.S. Shareholders, More Attribution, More Compliance
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.").
United States
12 Apr 2018
Partner Representatives And The New Partnership Audit Regime
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.
United States
14 Mar 2018
A New Opportunity For Nonresident Aliens – Ownership In An S-Corp
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.
United States
13 Mar 2018
Non-Corporate Taxation: Individuals & Partnerships Face Highs & Lows Under The T.C.J.A.
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.
United States
12 Mar 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
Qualified Business Income – Are You Eligible For A 20% Deduction?
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.
United States
8 Mar 2018
H.M.R.C. Issues Gift Tax Demands To Contributors To Brexit Referendum
Companies and financial institutions are not liable for inheritance tax and therefore do not face additional tax.
7 Feb 2018
E.U. Names U.S. Possessions As Non-Cooperative Jurisdictions For Tax Purposes
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.
7 Feb 2018
Expired Individual Tax Identification Numbers
Federal returns that are submitted in 2018 with an expired I.T.I.N. will be processed.
United States
7 Feb 2018
Income Shifting: Common Ownership Or Control Under Code §482 In An Inbound Transaction
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 ...
United States
6 Feb 2018
Individual, Corporate, And Trust News From France
As explained in the January 2017 edition of Insights, the end of the year in France is always marked by a fiscal legislative process to amend the current year's finance law ...
6 Feb 2018
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