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By Beate Erwin, Astrid Champion, Nina Krauthamer
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...
By Rusudan Shervashidze, Nina Krauthamer
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.
By Galia Antebi
While the U.S. still refuses to sign onto the O.E.C.D.'s Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the "CbC M.C.A.A."), the I.R.S. is making progress...
By Stanley Ruchelman, Beate Erwin
In Rev. Rul. 91-32, the I.R.S. announced its view that foreign partners in partnerships operating in the U.S. are properly taxed on their capital gains under a look-thru rule to the assets owned by...
By Alev Fanny Karaman, Beate Erwin
In today's start-up world, angel investing1 is a typical part of an entrepreneur's rou¬tine.
By Astrid Champion, Nina Krauthamer
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.
By Michael Peggs
In finding for the taxpayer in a recent transfer pricing decision, the U.S. Tax Court followed its own determination in Veritas in valuing a buy-in payment made as compensation...
By Philip Hirschfeld
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...
By Elizabeth V. Zanet, Stanley Ruchelman
Change driven by development of intellectual property ("I.P.") is now a constant. Whether the I.P. user is a tax adviser accessing a digital library, an auto mechanic interfacing with an engine...
By Galia Antebi
The U.S. applies a worldwide tax system imposed on residents and citizens alike.
By Rusudan Shervashidze, Stanley Ruchelman
In early April, Bloomberg News reported on coordinated tax raids on three separate offices of Credit Suisse.
By Alev Fanny Karaman, Galia Antebi
The foreign tax credit ("F.T.C.") is a keystone of U.S. outbound tax legislation.
By Alev Fanny Karaman, Beate Erwin, Stanley Ruchelman
As explained in an earlier article,1 a common civil law estate planning technique involves an older generation making a gift of bare ownership in an income generating asset to members of a younger generation.
By Alev Fanny Karaman, Stanley Ruchelman
Splitting ownership into usufruct and bare ownership is a common estate planning technique in several civil law countries.
By Alev Fanny Karaman
While a French-U.S. perspective is reflected in this article, most foreign tax lawyers practicing in the U.S. may find part of their own experience mirrored here.