Article 31 Mar 2025 When Baskets Go Beyond Weaving – Understanding Foreign Tax Credit Baskets Under The Look-Through Rules United States Tax
Article 14 Feb 2024 The Unravelling Of The Matryoshka Doll – Impact Of The C.T.A. On Entities Having Nexus To The U.S. United States Commercial
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 United States Commercial
Article 04 Dec 2023 Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids Worldwide Tax
Article 01 Dec 2022 Late Filed Form 3520: What Penalties To Expect And How To Respond United States Tax
Article 03 Feb 2022 The More You Know, The More You Don't Know – U.S. Tax Issues On A Disposition Of A Foreign Business United States Tax
Article 02 Dec 2021 Rescission – Undoing A Transaction That Seemed Like A Good Idea At The Time United States Commercial
Article 14 Jul 2021 The 15 Most Important Questions That Should Be Asked When Estate Planning For A Foreign Parent With U.S. Children United States Tax
Article 31 Dec 2020 Same Same, But Different: Taxation Of The Sale Of Stock Of An Indian Copany By A U.S. Person United States Tax
Article 09 Dec 2020 With Great Power (Control) Comes Great Responsibility – Form 5471 Category 4 Filer United States Tax
Article 07 Oct 2020 Final G.I.L.T.I. High-Tax Regulations And The Tested Unit: Would A Rose By Any Other Name Smell As Sweet? United States Tax
Article 11 Jun 2020 Heads I Win, Tails You (I.R.S.) Lose – Not Anymore: Hybrid Dividends And Code §245A(e) United States Tax
Article 08 Apr 2020 Variety Is The Spice Of Life: Alternate Tax Structures For A U.S. Individual Disposing Of Foreign Real Property United States Tax
Article 29 Nov 2019 Domestic Partnerships Treated As Entities And Aggregates: New Approach For G.I.L.T.I. And Subpart F United States Tax
Article 04 Oct 2019 Preferred Yet Neglected — A Plea For Guidance On Redemptions Of C.F.C. Preferred Stock In The Wake Of U.S. Tax Reform United States Commercial
Article 10 Jul 2019 Is The 100% Dividend Received Deduction Under Code §245A About As Useful As A Chocolate Teapot? United States Tax
Article 18 Jun 2019 Peeling The Onion To Allocate Subpart F Income – This Will Make You Cry! United States Tax
Article 20 May 2019 It's Time For Cayman Shell Entities To Come Out Of Their Shells And Show Economic Substance Cayman Islands Finance
Article 11 Apr 2019 More Permanent Establishments: The Dwindling Preparatory And Auxiliary Activities Exception United States Tax