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By Beate Erwin
The New York Times reported recently that the National Basketball Association ("NBA") and Major League Baseball ("MLB") are reaching out to both Congress and the Trump administration to learn more...
By Rusudan Shervashidze, Nina Krauthamer
In IR-2018-131, issued on June 4, 2018, the I.R.S. announced that it will waive certain late-payment penalties relating to the Code §965 transition tax ...
By Elizabeth V. Zanet
The I.R.S. Large Business and International division ("LB&I") recently announced the approval of the following six additional compliance campaigns:
By Alev Fanny Karaman, Stanley Ruchelman
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 ...
By Simon H. Prisk
In previous articles we have discussed the relative flexibility of limited liability companies ("L.L.C.'s"), which are generally taxed as partnerships ...
By Neha Rastogi, Beate Erwin
Foreign students leaving their home country and arriving in the U.S. for higher education may come across many things that seem alien to them – like the accent, culture, (inexplicably large) food portions, etc.
By Michael Peggs
The arrival of an information document request ("I.D.R.") for transfer pricing documentation often comes as a surprise to a company.
By Elizabeth V. Zanet, Beate Erwin
The I.R.S. recently issued Notice 2018-28, announcing that it intends to release regulations on various issues pertaining to the limitation on the deductibility of certain interest payments...
By Rusudan Shervashidze, Stanley Ruchelman
In the procedural maze that leads to a trial in the U.S. Tax Court, motion practice is an important part of tailoring issues presented to the court.
By Elizabeth V. Zanet, Galia Antebi
Under Code §962, an individual U.S. Shareholder may elect to be treated as a domestic C-corporation for the purpose of computing income tax on its share of Subpart F Income.
By Alev Fanny Karaman, Beate Erwin
In Europe, an individual's right to the protection of his or her personal data is a fundamental right.
By Ruchelman PLLC
Effective January 1, 2018, Italy's 2018 Budget Law significantly amended the domestic definition of permanent establishment and implemented certain O.E.C.D. guidelines set forth under B.E.P.S. Action 1...
By Michael Peggs, Sheryl Shah
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
By Rusudan Shervashidze, Stanley Ruchelman
On the way toward a dividends received deduction for certain dividends paid by foreign subsidiaries, Congress enacted a one-shot income inclusion of all post-1986 earnings...
By Alev Fanny Karaman, Nina Krauthamer
When it comes to pre-immigration planning, there are greater opportunities when the individual moving to the U.S. is not yet a U.S. person for U.S. tax purposes: Various techniques are available...