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Ropes & Gray LLP
In this Ropes & Gray podcast, tax partners Adam Greenwood and Dan Kolb, and asset management partner Isabel Dische discuss the recently finalized ECI withholding regulations...
Frost Brown Todd
In an earlier article titled "Rollover Equity Transactions 2019," we discussed the various business and tax issues associated with transactions involving private equity (PE) buyers...
Fenwick & West LLP
This client alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986.
Ruchelman PLLC
Mr. Z is a U.S. resident under Code §7701(a)(30) for purposes other than the foreign tax credit. He is a Green Card Holder
Proskauer Rose LLP
On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the "Act").
Morrison & Foerster LLP
We looked at 28 deals across Asia that were signed or closed pre-COVID in which the buyer or a group of affiliated buyers acquired all ...
Akin Gump Strauss Hauer & Feld LLP
During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial
Proskauer Rose LLP
On November 17, 2020, the U.S. Internal Revenue Service ("IRS") posted new FAQs providing that an acquisition of the stock or assets of a company that has received a loan under the Paycheck Protection Program.
Ruchelman PLLC
Obtaining an I.TI.N. is done by completing Form W-7, Application for I.R.S. Individual Taxpayer Identification Number.
Holland & Knight
The U.S. Department of the Treasury (Treasury) issued proposed regulations (the Proposed Regulations) on April 8, 2020, that would restrict foreign persons' ability to minimize U.S...
Reinhart Boerner Van Deuren s.c.
As the end of the year nears, a U.S. subsidiary may try to repatriate cash to its foreign parent. Repatriation may occur in several different methods with each having advantages and disadvantages.
Mayer Brown
Congress reacted swiftly to the Tax Court decision holding that no withholding tax should be imposed on the disposition of a partnership interest by a non-US investor in a partnership that was engaged in the conduct of a US trade or business.
Withers LLP
With the impact of rampant U.S. federal government stimulus spending to address the coronavirus pandemic and the continuing impact of tax cuts under the 2017 Tax Cuts and Jobs Act (TCJA), the...
Shearman & Sterling LLP
On October 7, 2020, the U.S. Department of Treasury ("Treasury") and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the "Final Regulations") with respect to the ...
Holland & Knight
The IRS Large Business & International Division (LB&I) announced on Oct. 5, 2020, the latest IRS audit campaign targeting nonresident aliens (NRA)
Ostrow Reisin Berk & Abrams
With the presidential election only weeks away, many people are beginning to pay closer attention to each candidate's positions on such issues as the COVID-19 pandemic, health care...
Withers LLP
This article is produced by Withers real estate planning think tank, a group focused on innovative thinking and practical applications for our clients investing in US real estate.
Cadwalader, Wickersham & Taft LLP
SIH Partners, a Delaware partnership, filed a petition in Tax Court challenging the IRS's reclassification of $171 million of reported qualified dividend income (QDI) from Swiss stocks as ordinary dividend income for its 2012 tax year.
Cadwalader, Wickersham & Taft LLP
Following on from the second part in this series, which looked at the proposal under Pillar One, the third and penultimate part in this series will examine the proposal under Pillar Two.
TMF Group BV
TMF Group全球会计与税务解决方案总监Emine Constantin在本文中探讨了数字技术对全球税务体系带来的挑战,以及各国如何通过征收数字服务税解决这一问题。
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