News & Analysis as of

International Tax Issues Penalties

Hone Maxwell

Understanding FATCA and Its Impact on Foreign Financial Institutions: Why Finding Financial Services as an American Abroad Can Be...

Hone Maxwell on

As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more

Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more

Bilzin Sumberg

Do You Know Where Your Gift or Bequest Is Coming From? If Not, You May Be Subject to a Gift/Inheritance Tax and the Related New...

Bilzin Sumberg on

Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

Hone Maxwell on

Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards

Join us for an insightful episode of “GILTI Conscience” as David Farhat, Eman Cuyler and Stefane Victor — together with our special host Skadden tax partner Loren Ponds and guest Fernando Colucci, partner at Machado Meyer in...more

Mayer Brown

Caractérisation d’un établissement stable dans le domaine du digital en présence d’une activité occulte

Mayer Brown on

Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...more

Allen Barron, Inc.

Serious Challenges for Expats and Those Considering Moving Abroad

Allen Barron, Inc. on

The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more

Morgan Lewis

Key Takeaways: US-Canada Transfer Pricing & Tax Controversies: What’s New, What’s Not, and How to Prepare for Both

Morgan Lewis on

The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Offit Kurman

Forgetting to File International Forms

Offit Kurman on

Welcome to “Lost in Translation: Blunders in International Estate Planning.” This blog series explores the rarified world of international estate planning, uncovering potential pitfalls and providing insights to navigate the...more

Sheppard Mullin Richter & Hampton LLP

New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more

McDermott Will & Emery

Russian Transfer Pricing Law

McDermott Will & Emery on

Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more

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