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Searching Content indexed under Withholding Tax by Ruchelman PLLC ordered by Published Date Descending.
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1
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
2
Debt Characterization And Deductibility Under Domesticated International Rules
The limitation of interest deductibility to approximately 30% of E.B.I.T.D.A. (earnings before interest, tax, depreciation, and amortization) introduced in amended Code ง163(j) has focused the attention of U.S. corporations ...
United States
9 Jul 2019
3
Anti-Tax Arbitrage The U.S. Way
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced two new rules targeting hybrid arrangements. The first deals with hybrid dividends.
United States
20 May 2019
4
Democrats Turn To Tax Reform To Reduce Wealth Disparity
The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...
United States
12 Apr 2019
5
Proposed Amendments To F.A.T.C.A. Suggest Reducing Or Deferring Withholding
On December 13, 2018, the I.R.S. issued proposed regulations under Code งง1471 through 1474 (F.A.T.C.A provisions) as well as under Code งง1441 and 1461 (withholding on non-U.S.
United States
11 Mar 2019
6
Who's Got The B.E.A.T.? A Playbook For Determining Applicable Taxpayers And Payments
Code ง59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax
United States
11 Mar 2019
7
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
8
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
9
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
10
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
11
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
12
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
13
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 ...
France
6 Feb 2018
14
Employment Tax Basics And Paths To Compliance
When non-U.S. entities expand to the U.S., they face several issues, all of them new.
United States
11 Dec 2017
15
The Sharing Economy Part 2: Governments Strike Back
The current international tax system was established at a time when the sharing economy did not exist and was not foreseeable.
United States
5 Dec 2017
16
Updates And Tidbits
When claiming a refund of over-withheld tax, purchasing or selling real property, or complying with U.S. filing requirements, a non-U.S. individual is required to obtain an I.T.I.N. from the I.R.S...
United States
19 Jul 2017
17
Code ง163(J) – Ignoring U.S. Thin Capitalization Rules May Leave Tax Advisors Thinly Prepared For Audits
Using deductible interest payments to reduce U.S. taxable income is often a goal of tax practitioners.
United States
9 May 2017
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