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Searching Content indexed under Tax Authorities 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
2
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
3
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
4
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
5
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
6
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
7
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
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