Searching Content indexed under Corporate/Commercial Law by Ruchelman PLLC ordered by Published Date Descending.
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Domestic Partnerships Treated As Entities And Aggregates: New Approach For G.I.L.T.I. And Subpart F
The effect of the T.C.J.A. continues to be encountered in unexpected ways during the second year after its enactment.
United States
29 Nov 2019
F.I.R.R.M.A. Proposed Regulations Expand C.F.I.U.S. Oversite On Foreign Investment
On August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 ("F.I.R.R.M.A.") was signed into law after receiving broad bipartisan support in Congress.
United States
8 Oct 2019
United States
4 Oct 2019
Grecian Magnesite Put To Bed: Tax Court Ruling Affirmed On Appeal
Recently, the Court of Appeals for the D.C. Circuit affirmed the 2017 Tax Court ruling in the matter of Grecian Magnesite Mining v. Commr., which held that a foreign corporation was not liable for U.S. tax on the gain ...
United States
11 Jul 2019
United States
10 Jul 2019
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
Peeling The Onion To Allocate Subpart F Income – This Will Make You Cry!
There has been a wealth of conversation addressing the amendment to the definition of a "U.S. Shareholder" in the context of a controlled foreign corporation introduced by the 2017 Tax Cuts and Jobs Act.
United States
18 Jun 2019
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
The I.R.S. Approach To Dependent Agent Status
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
United States
11 Apr 2019
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
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
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
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
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
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
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
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
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.
18 Oct 2018
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
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
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