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Searching Content indexed under Financial Services by Ruchelman PLLC ordered by Published Date Descending.
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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
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
Corporate Matters: Delaware Law Allows L.L.C. Divisions
In 2018, Delaware amended its limited liability company act to add Section 18-217, which enables an L.L.C. to divide into two or more newly formed L.L.C.'s, with the dividing company either continuing or terminating its existence.
United States
20 Jun 2019
4
Proposed F.D.I.I. Regulations: Deductions, Sales, And Services
On December 22, 2017, the Tax Cuts and Jobs Act 2017 ("T.C.J.A.")1 introduced the foreign derived intangible income
United States
18 Jun 2019
5
It's Time For Cayman Shell Entities To Come Out Of Their Shells And Show Economic Substance
In response to the O.E.C.D.'s B.E.P.S. recommendations and the conclusions and concerns identified by the E.U. Code of Conduct Group of Business Taxation,
Cayman Islands
20 May 2019
6
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
7
F.B.A.R.'s – What You Need To Know
April 15 is almost here, and while most people know this date as the filing deadline for individual tax returns, it also important to another filing requirement:
United States
11 Apr 2019
8
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
9
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
10
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
11
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
12
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
13
U.K. Requirement To Correct
The "Requirement to Correct" ("R.T.C.") rules became law when the Finance (No. 2) Act 2017 received Royal Assent on November 16, 2017.
UK
7 Aug 2018
14
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
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