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Womble Bond Dickinson
On June 22, 2022, Henry McMaster, the Governor of South Carolina, signed South Carolina Bill 901 (the "Bill") into law. The Bill amends the Enterprise Zone Act of 1995's section...
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.
Mayer Brown
After approximately 18 months of taxpayer anticipation, the US Internal Revenue Service ("IRS") has released Notice 2022-23.
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
Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement...
On December 28, 2021, Treasury and the IRS (collectively, Treasury) submitted another package of final foreign tax credit regulations for publication, T.D. 9959, 87 FR 276 (Final Regulations).
Ruchelman PLLC
A sale of a business to a buyer often involves an element of goodwill, a term that can have different meanings in different contexts, depending on whether the term relates...
Haynsworth Sinkler Boyd
Each year, South Carolina's 46 counties are designated as being within one of four "tiers" for job tax credit and job development credit purposes based on a county's unemployment rate and per capita income.
Alston & Bird
On December 28, 2021, the Treasury Department and the IRS issued another tranche of final foreign tax credit (FTC) regulations, which were officially published in the Federal Register on January 4, 2022.
Holland & Knight
Withholding tax rules in which the former spouse receiving the alimony payments is a non-U.S. person and the payor spouse is a U.S. person have been affected.
In May 2021, President Biden's administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean energy and certain infrastructure projects.
Cadwalader, Wickersham & Taft LLP
On September 15, 2021, the House Ways and Means Committee approved tax provisions for proposed inclusion in the Build Back Better Act (the BBBA)...
Cadwalader, Wickersham & Taft LLP
This chart compares the Biden Administration's Fiscal Year 2022 Revenue Proposals (the Greenbook), which we discuss here, to the tax proposals in the Build Back Better Act (BBBA) approved by the ...
Cooley LLP
Last week, the House Ways and Means Committee announced its consideration of federal tax legislative proposals that include reducing the exclusion from income of gain on the sale of qualified...
Holland & Knight
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations...
Holland & Knight
•The United Kingdom and the U.S. Competent Authorities have entered into a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty)
Mayer Brown
The Biden administration has set forth an array of big ticket proposals since taking office and at least one thing seems to be clear: increased enforcement by the Internal Revenue Service (the "IRS") is on the horizon.
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 ...
Freeman Law
Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers.
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