Searching Content indexed under Corporate and Company Law by Ruchelman PLLC ordered by Published Date Descending.
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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
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
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
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
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
Partner Representatives And The New Partnership Audit Regime
Commencing in January 2018, the I.R.S. began a new centralized audit regime with respect to partnerships. It replaces the concept of a "Tax Matters Partner" with a "Partnership Representative.
United States
14 Mar 2018
A New Opportunity For Nonresident Aliens – Ownership In An S-Corp
Changes to U.S. tax law brought about by the 2017 Tax Cuts and Job Act ("T.C.J.A.") have affected many longstanding tax planning tools.
United States
13 Mar 2018
The Sharing Economy Part 1:New Business Models +Traditional Tax Rules Don't Mix
The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.
United States
17 Nov 2017
Foreign Partner Not Subject To U.S. Tax On Gain From Redemption Of U.S. Partnership Interest
In Grecian Magnesite Mining, Industrial & Shipping Co., S.A. v. Commr.,1 the U.S. Tax Court recently held that a foreign partner was not subject to U.S. Federal tax when it redeemed its interest in a U.S. partnership...
United States
30 Aug 2017
I.R.S. Breaks The Silence With Rev. Rul. 2017-09, Issues Guidance On "North-South" Transactions
On May 3, 2017, the I.R.S. issued Rev. Rul. 2017-09, 2017-21 I.R.B. 1244, which clarifies "north-south" transactions in two factual situations.
United States
18 Jul 2017
Qualified Small Business Stock & The Eb-5 Visa Program – An Attractive Combination For Potential Investors
In today's start-up world, angel investing1 is a typical part of an entrepreneur's rou¬tine.
United States
13 Jul 2017
Wealth Tax Burden In Ireland Does Not Entail Residency Under U.S.-Ireland Tax Treaty
On March 3, 2017, the U.S. Court of Federal Claims ruled that a taxpayer's liability for the domicile levy in Ireland does not qualify him as a resident of the country under the U.S.-Ireland Income Tax Treaty.
United States
15 Jun 2017
Net Operating Losses: A Valuable Asset Worth Preserving
Every cloud has a silver lining. This expression also applies to the world of tax. Troubled companies that incur significant operational and interest expenses may find that they have generated...
United States
13 Jun 2017
LB&I Audit Insights: Using A Code §6038A Summons When A U.S. Corporation Is 25% Foreign Owned
The I.P.U. acknowledges that exceptions are provided for small corporations and transactions of de minimis value.
United States
11 May 2017
Tax Concerns On Outbound I.P. Transfers: Pitfalls & Planning
In a 21st century America where new ideas continually create new intangible property, U.S. corporations often desire to contribute their I.P. to a foreign affiliate who then develops and...
United States
10 May 2017
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