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Substantial Presence? PE? Treasury and the IRS prescribe treatment for tax maladies

The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may be able to work remotely,...more

GILTI by consolidation

Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more

IRS to crackdown on SALT deduction Cap workarounds

On May 23, 2018, the IRS and the Treasury Department issued Notice 2018-54 announcing their intention to propose regulations addressing the federal tax treatment of state workarounds to the $10,000 ($5,000 in the case of...more

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