News & Analysis as of

Investment › Foreign Tax Credits

Proskauer - Employee Benefits & Executive...

Eleventh Circuit Confirms Foreign Tax Credits Owned by Insurance Company Not “Plan Assets” of 401(k) Plan Under ERISA

Proskauer - Employee Benefits & Executive... on

In late October 2024, the United States Court of Appeals for the Eleventh Circuit ruled in Romano v. Hancock Life Insurance Company, F.4th 729 (11th Cir. 2024) that certain foreign tax credits that were generated as a result...more

McDermott Will & Schulte

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

McDermott Will & Schulte on

In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more

McDermott Will & Schulte

International News: Spotlight on Tax

McDermott Will & Schulte on

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Snell & Wilmer

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Snell & Wilmer on

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

4 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide