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By Rusudan Shervashidze, Nina Krauthamer
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.
By Alev Fanny Karaman, Galia Antebi
Blockchain has recently been in the spotlight, mostly due to the 2017 surge in cryptocurrency values and the rise of initial coin offerings ("I.C.O.'s").
By Gary Ashford
The "Requirement to Correct" ("R.T.C.") rules became law when the Finance (No. 2) Act 2017 received Royal Assent on November 16, 2017.
By Elizabeth V. Zanet, Stanley Ruchelman
When financial analysts of a financial institution review the tax provision of potential customers incident to a financial transaction, the focus typically is directed at current and deferred taxes...
By Elizabeth V. Zanet, Rusudan Shervashidze
On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code §965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders...
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.