On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
1/4/2024
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With the holiday season upon us, we thought it would be a good idea to review some of the gift tax rules uniquely applicable to foreign clients. This post examines the rules surrounding one type of gift in particular – the...more
The IRS recently released its annual Revenue Procedure containing inflation-adjustments for 2021. Of interest to international tax and estate planning practitioners are the following...more
On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b)....more