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Foley Hoag LLP
Cayman Islands investment entities are currently subject to three separate regimes relating to financial account information reporting: U.S. FATCA, U.K. FATCA and the OECD Common Reporting Standard (CRS).
Morrison & Foerster LLP
On April 4th, the IRS issued proposed regulations under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax purposes.
Caplin & Drysdale
In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners.
"Some people say not to worry about the air. Some people have never had experience with air."
On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping.
Nutter McClennen & Fish LLP
Last month in this blog, we described five ways to be diligent about documenting charitable gifts of cash or out-of-pocket expenses to preserve your tax deduction. But what about gifts of property – does giving something other than cash change the taxpayer's responsibilities? According to the tax regulations, the answer is no and yes.
Steptoe & Johnson LLP
One of the most publicized and long-awaited business provisions contained in the Omnibus Budget Reconciliation Act of 1993, P.L. 103-66, 107 Stat. 312 (1993) (the "1993 Act") was section 197 of the Internal Revenue Code of 1986 (the "Code"), which governs the tax treatment of acquired intangible assets. However, section 197 cannot be analyzed in isolation. Since it comes into play whenever there is an allocation of consideration to an amortizable section 197 intangible, a basic understanding of
Grant Thornton LLP
President Barack Obama signed the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA) which makes permanent the moratorium on Internet access taxes and multiple or discriminatory taxes on electronic commerce established by the Internet Tax Freedom Act.