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Double Taxation › Internal Revenue Code (IRC)

Orrick, Herrington & Sutcliffe LLP

UK Founder Series: Flip Back from the U.S. – Key U.S. Tax Considerations

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Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

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As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Fenwick & West LLP

Bruyea v. United States - Latest Foreign Tax Credit Case on the NIIT Sheds Important Light on Treaty Double Tax Articles

Fenwick & West LLP on

Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more

Allen Barron, Inc.

A New Wave of U.S. Expatriate Income Tax Refund Applications?...

Allen Barron, Inc. on

Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

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The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Freeman Law

Tax Court in Brief | Smith v. Comm’r | Closing Agreement and Malfeasance of Fact

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Short Summary:  The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more

Foley & Lardner LLP

401(k) Compliance Check #9: Too Much of a Good Thing – 401(k) Plan Excess Deferrals

Foley & Lardner LLP on

To help employers properly administer their 401(k) plans, in 2022, Foley & Lardner LLP is authoring a series of monthly “401(k) Compliance Check” newsletters. This article discusses the IRS limits on 401(k) plan contributions...more

Freeman Law

Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit.

Freeman Law on

As discussed in a previous article, the Foreign Tax Credit (FTC) is a bedrock of the U.S. tax system to reduce the impact of double taxation. In general terms, income that is derived from a foreign jurisdiction by a U.S....more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

Foodman CPAs & Advisors on

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Burr & Forman

Where Did All The "S" Corporations Come From?

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You just formed your medical practice in Alabama, and you either chose a professional corporation (a "PC") or an LLC. If you went with a PC, you get to choose between an "S" corporation ("S corp") or a "C" corporation ("C...more

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