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Double Taxation Internal Revenue Service International Tax Issues

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...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

Allen Barron, Inc.

Foreign Corporate Ownership and Investments

Allen Barron, Inc. on

Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

A&O Shearman on

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

Freeman Law

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

Freeman Law on

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

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?

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

Brownstein Hyatt Farber Schreck

Taxation & Representation - June 2019 #3

TAX TIDBIT - Five Takeaways and a Falsehood: Test Your Knowledge of the Ways and Means Tax Markup - On Thursday, the House Ways and Means Committee marked up and approved the following four bills, largely along...more

Fox Rothschild LLP

Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping

Fox Rothschild LLP on

Statutory Background- When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S. has entered...more

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