Mondaq USA: Tax > Tax Treaties
Withers LLP
Several recent rulings concerning the tax exemption applicable to institutional investors into Italian real estate investment funds ("*REIFs*")
BakerHostetler
Below is the Federal Policy team's weekly preview, posted when Congress is in session
Ruchelman PLLC
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:
Ropes & Gray LLP
In its 2019 Spring Term, the Supreme Court published five decisions regarding tax matters, three of which limit states' taxing authority.
Mayer Brown
On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)
Ruchelman PLLC
On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.
Ruchelman PLLC
On June 25, the Senate Foreign Relations Committee approved protocols to four income tax treaties, clearing the way for the treaties to be considered by the full Senate.
Duff and Phelps
The document is intended to be used as a starting point for tax treaty negotiations between jurisdictions.
Duane Morris LLP
On May 1, 2019, the United States Department of Justice announced that a U.S. federal court had authorized the Internal Revenue Service to serve a so-called "John Doe" summons to several U.S. financial institutions.
Cadwalader, Wickersham & Taft LLP
The DOJ petitioned the U.S. District Court for the Western District of North Carolina to authorize IRS summonses to uncover the identities of Finnish residents using U.S.-issued payment cards in Finland.
Duff and Phelps
The French government estimates that the DST would raise approximately 500 million Euros per year.
Ropes & Gray LLP
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
Ruchelman PLLC
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
Ruchelman PLLC
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.
Cadwalader, Wickersham & Taft LLP
U.S. domiciliaries are generally subject to U.S. Federal estate tax, gift tax and generation-skipping transfer tax (the "GST tax") in the same manner as U.S. citizens
Davies Ward Phillips & Vineberg
U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA).
Ruchelman PLLC
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax
Ruchelman PLLC
Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").
Ropes & Gray LLP
The term ‘private equity' is defined by the British Private Equity and Venture Capital Association as ‘any medium to long term finance provided in return for an equity stake in potentially high
Hunton Andrews Kurth LLP
Brexit—the formal departure of the United Kingdom (the UK) from the European Union (the EU), pursuant to the referendum held in the UK in June 2016—is imminent: the UK will cease to be a member of the EU on March 29, 2019.
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Ruchelman PLLC
The first step in advising a foreign individual who is neither a U.S. citizen nor a green card holder on U.S. income tax laws is to determine the person's residence ...
BakerHostetler
Below is the Federal Policy team's weekly preview, posted when Congress is in session
Ruchelman PLLC
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:
Ruchelman PLLC
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.
Davies Ward Phillips & Vineberg
U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA).
Ropes & Gray LLP
The term ‘private equity' is defined by the British Private Equity and Venture Capital Association as ‘any medium to long term finance provided in return for an equity stake in potentially high
Davies Ward Phillips & Vineberg
The United States was initially reluctant to adopt the recommendations of the base erosion and profit shifting (BEPS) initiative spearheaded by the OECD and the G20 group of nations.
Ruchelman PLLC
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
Ruchelman PLLC
On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.
Proskauer Rose LLP
On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
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