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Mayer Brown
The proposed regulations identify 24 types of issues that will not trigger Appeals rights.
Freeman Law
As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy one of two tests: the green card test or ...
Freeman Law
A taxpayer's status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien...
Mayer Brown
In this article, the authors examine the necessity of including a multilateral instrument in the inclusive framework workplan...
Brownstein Hyatt Farber Schreck, LLP
Reconciliation Revival? Ever since Sen. Joe Manchin (D-WV) publicly renounced his support of the House-passed Build Back Better Act (BBBA)
Mayer Brown
On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.
Mayer Brown
On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.
Bilzin Sumberg Baena Price & Axelrod LLP
For starters, the test operates not on a single-year basis but on a rolling basis under which days are weighted in order to arrive at the 183 day total.
Ruchelman PLLC
A U.S. taxpayer that is subject to income tax in both the U.S. and a foreign country can reduce the amount of tax payable to the U.S. by claiming a credit for foreign income taxes paid or accrued...
Freeman Law
Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions.
Ruchelman PLLC
his article will explore two cases where arbitration under a B.I.T. provided ephemeral benefits.
Bilzin Sumberg Baena Price & Axelrod LLP
The United States is no stranger to capital from foreign investors.
Ruchelman PLLC
The common law revenue rule is a judicial doctrine that prevents courts in one country from being used by a foreign government as a tool to collect lost tax revenue of any kind. As explained by one...
Mayer Brown
In April, the IRS released a practice unit on country-by-country (or "CbC") reporting. The purpose of the document is twofold: (i) describe the background of CbC reporting...
Mayer Brown
On March 22, 2022, the Internal Revenue Service's Advance Pricing and Mutual Agreement Program released its 2021 Announcement and Report Concerning Advance Pricing Agreements.
Cadwalader, Wickersham & Taft LLP
On 22 March 2022, the Organisation for Economic Co-operation and Development ("OECD") published a public consultation document proposing new and amended reporting requirements with respect to...
Freeman Law
Generally, income from the sale of personal property is "sourced" to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed to be the United States.
Brownstein Hyatt Farber Schreck, LLP
Brownstein Budget Breakdown. The Brownstein Tax Policy team has gone through the thousands of pages and countless spending tables to compile a summary and analysis...
Freeman Law
A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. Payments of U.S.-source "fixed and determinable annual or periodic...
Freeman Law
Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers.
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