United States: Tax Treaties

Many of our clients are interested in engaging in global philanthropy. These individuals often want to benefit charitable causes outside of the United States while still being able to maintain an income tax deduction ...

§ 2801 of the Internal Revenue Code of 1986, as amended (the "Code") imposes a tax a U.S. citizen or resident who receives a "covered gift" or "covered bequest" from certain individuals...

The application of the foreign tax credit to the net investment income tax ("N.I.I.T.") has been a recurring battle in courtrooms in recent years. In the most recent installment...

Whatever one may believe about climate change, there is no denying that there has been a series of natural disasters over the past decade. Most recent was the devastation of the January 2025 fires in Southern California.

While the estate and gift tax exemption is at an all time high in 2025, this could change dramatically in 2026. Accordingly, for 2025, please consider the following updates and planning considerations.

Many people may feel taxed to death, but it's actually more than that. After you die, there may still be taxes to pay. Death can be a tax-triggering event. And there are two you should be aware of: the estate tax.

It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse.

According to the IRS, most cancellations of debt are taxable. When taxpayers are relieved from the legal obligation to repay a loan, they must recognize this cancellation of debt...

On April 7, the Maryland legislature passed House Bill 352 and sent it to Gov. Wes Moore for him to sign into law. If enacted without any line-item vetoes affecting the provisions below...

Riveron's M&A Tax and Transaction Services experts have observed the latest changes and evolving trends related to US trade and tariff policies and have participated in several discussions on the potential impacts.

The IRS has issued guidance endorsing a muscular approach to the application of "periodic adjustments" provisions. Those provisions authorize IRS adjustments of a taxpayer's pricing for transfers of high-value intangibles, including platform contribution transactions, for taxable years after the year of transfer, based on the actual, realized profitability of those intangibles in those later years

Federal courts next year are set to decide several cases that could shape how international tax planners will account for uncertainty and enforcement risks in 2025 and beyond.