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1
Holding Companies Of Europe – Tax Planning For European Expansion In A Changing Landscape
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: (i) the reduction of European taxes ...
United States
15 Jan 2019
2
How To Handle Dual Residents: The I.R.S. View On Treaty Tie-Breaker Rules
The first step in advising a foreign individual who is neither a U.S. citizen nor a green card holder on U.S. income tax laws is to determine the person's residence ...
United States
12 Dec 2018
3
C-Corps Exempt From Full Scope Of Foreign Income Inclusion
On October 31, 2018, the I.R.S. proposed regulations affecting controlled foreign corporations ("C.F.C.'s") and U.S. corporations that are considered to be U.S. Shareholders ...
United States
12 Dec 2018
4
A Deep Dive Into G.I.L.T.I. Guidance
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced a new anti-abuse tax regime applicable to controlled foreign corporations ("C.F.C.'s").
United States
12 Dec 2018
5
Transition Tax – Proposed Regulations Are Here
The Treasury Department and the I.R.S. recently published proposed regulations on Code ง965 (the "Proposed Regulations").
United States
12 Nov 2018
6
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 ง199A, 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
7
New York And Neighboring States Bring Action Against The Federal Government
The new limitation on the deduction will increase the cost of owning a home, which will in turn depress home values.
United States
18 Oct 2018
8
Cristiano Ronaldo's Move To Italy – Was It For Love Of The Game Or The Tax Law?
Colombian singer Shakira, was also ordered to pay more than €20 million in back taxes to Spain
Italy
18 Oct 2018
9
Happy Ending For The Home Of The Happy Meal – No Illegal State Aid To McDonald's
On September 19, 2018, the European Commission issued a decision that nontaxation of certain McDonald's profits in Luxembourg was not illegal State Aid.
Worldwide
18 Oct 2018
10
D.O.J. Resorts To Undercover Operations To Secure First Conviction Under F. A.T.C.A.
Mr. Baron was extradited to the U.S. from Hungary in July.
United States
18 Oct 2018
11
O.E.C.D. Discussion Draft On Financial Transactions – A Listing Of Sins, Little Practical Guidance
The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.
United States
18 Oct 2018
12
Tax Considerations Of I.P. When Expanding A Business Offshore
The U.S. person must prepare a valuation of the intangible property in accordance with rules set forth in the Treasury regulations.
United States
18 Oct 2018
13
F.A.T.C.A. – Where Do We Stand Today?
A participating F.F.I. files Form 8966, F.A.T.C.A. Report, annually with the I.R.S. The
United States
18 Oct 2018
14
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
15
Hybrid Mismatches: Where U.S. Tax Law And A.T.A.D. Meet
This article focuses on the interaction between certain hybrid mismatch provisions of A.T.A.D. 2 and certain provisions of U.S. tax law.
United States
2 Oct 2018
16
Tax Basics Of Intellectual Property
Like most assets developed, used, and sold in business, intellectual property (IP) is subject to important tax considerations.
United States
2 Sep 2018
17
Outbound Acquisitions: Holding Companies Of Europe – A Guide For Tax Planning, Or A Road Map For Difficulty?
When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.
United States
30 Aug 2018
18
2018 Holding Companies Of Europe – Tax Planning For European Expansion In A Changing Landscape
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
30 Aug 2018
19
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
20
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
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