Article
04 Jun 2025
Budget Resolution Tax Provisions Contain Reprisal Tax Aimed At O.E.C.D. Proposals
RANKINGS
This author falls within the Top 20% for their listed topics and industry categories. Based on Mondaq users readership, this author is ranked as VERY POPULAR in United States
AUTHORS CONTENT
Article
31 Mar 2025
When Baskets Go Beyond Weaving – Understanding Foreign Tax Credit Baskets Under The Look-Through Rules
Article
05 Jun 2024
Information Reporting On Foreign Trusts And Gifts – New Regulations Proposed
Article
14 Feb 2024
The Unravelling Of The Matryoshka Doll – Impact Of The C.T.A. On Entities Having Nexus To The U.S.
Article
07 Feb 2024
Receipt Of A Profits Interest In A Partnership By A Service Provider – Not Taxable
Article
07 Feb 2024
Will Service Automation Companies Qualify For The Q.S.B.S. Exemption?
Article
07 Dec 2023
Moore v. U.S. – A Case For The Ages To Be Decided By Supreme Court
Article
07 Dec 2023
Did You Just Manifest The Opposite Of What You Wanted - (In)Ability To Use G.I.L.T.I. Losses To Offset Gain
Article
07 Dec 2023
Is It Safe To Use A S.A.F.E.?
Article
04 Dec 2023
Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids
Article
06 Apr 2023
Tax Considerations For A U.S. Holder Of Bare Legal Title In A Usufruct Arrangement
Article
06 Apr 2023
Lost In Translation: Treatment Of Foreign-Law Demergers Under U.S. Federal Tax Law
Article
31 Jan 2023
Code §245a – Sometimes Things Are More Than They Appear
Article
01 Dec 2022
Late Filed Form 3520: What Penalties To Expect And How To Respond
Article
01 Dec 2022
Tax 101: Tricky Issues When A Non-U.S. Person Invests In An L.L.C. Or Partnership Operating In The U.S.
Article
30 Sep 2022
Tax 101: U.S. Tax Compliance For Dual Citizen Young Adults
Article
28 Jul 2022
Global Tax Planning In A Pre-2018 World
Article
31 May 2022
Perenco v. Ecuador And Achmea B.V. v. The Slovak Republic: Practical Limitations When Seeking Relief Under A B.I.T.
Article
19 May 2022
Adventures In Cross-Border Tax Collection: Revenue Rule vs. Cum-Ex Litigation
Article
05 May 2022
The Economic Substance Doctrine: A U.S. Anti-Abuse Rule