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Tax Treaties
United States
Lowenstein Sandler
Unlike most countries in the world, if you are a citizen or resident of the United States, the government gets to tax all of your worldwide income, regardless of where it's earned or where you live.
Miller & Chevalier Chartered
While the Speaker drama unfolds and we find ourselves in the middle of the third week of a paralyzed House, Tax Take turns its attention to some noteworthy international tax developments.
Miller & Chevalier Chartered
The anticipated government shutdown was avoided by the surprise bipartisan continuing resolution (CR), the Continuing Appropriations Act, 2024 and Other Extensions Act...
Cadwalader, Wickersham & Taft LLP
GE Financial Investments Limited ("GEFI Limited") was a UK incorporated and tax resident company and a member of the General Electric group.
Pillsbury Winthrop Shaw Pittman
On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey's Corporation Business Tax ("CBT"). The bill enacted a variety of clarifications, corrections, and modifications to the CBT.
Proskauer Rose LLP
If the bill is passed, it would deny the benefits of section 892 to several of the largest sovereign wealth funds by assets.
Caplin & Drysdale
One key component of the OECD's Pillar One proposal to reallocate taxing rights from producer to consumer nations is the promise that businesses and governments...
Greenberg Glusker Fields Claman & Machtinger
The concept of domicile is key to determining an individual's liability for US estate tax purposes.
The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation...
Mayer Brown
As countries around the world enact legislation implementing Pillar Two, the Republican majority of the House Ways & Means Committee has made no secret of its dissatisfaction with the Biden Administration's willingness...
Caplin & Drysdale
Peter Barnes co-wrote the May 22, 2023 letter "No Time for Waiting" for Tax Notes Today International. Below is the entire letter. Please visit this link to view the letter as it appears in Tax Notes Today International.
Greenberg Glusker Fields Claman & Machtinger
If you travel frequently to—or are considering moving to—the US, it's essential to understand US tax residency and how to manage tax and reporting obligations effectively to avoid complications.
Mayer Brown
On April 25, 2023, the IRS's Advance Pricing and Mutual Agreement ("APMA") Program issued new interim guidance for its review of taxpayer Advance Pricing Agreement ("APA") requests.
Ruchelman PLLC
Ask parents why they work as hard as they do, and many will answer that it is to give their children a better future. For some, this involves sending their children to foreign countries...
Ruchelman PLLC
The Bank Secrecy Act ("B.S.A.") requires U. S. persons with certain financial interests in foreign accounts to file an annual report known as an "F.B.A.R.," which is embodied
Ruchelman PLLC
If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.
Kramer Levin Naftalis & Frankel LLP
On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty)...
Miller & Chevalier Chartered
The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.
Holland & Knight
The U.S. Senate, in a vote of 95-2 on June 22, 2023, approved a Resolution of Advice and Consent (the Resolution) to ratify the Convention Between the Government of the United States...
Duane Morris LLP
On June 22, the U.S. Senate finally consented to the ratification of the United States-Chile income tax treaty by a 92-2 vote. The treaty was "initialed" in February 2010, but is still pending U.S. ratification.
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