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Internal Revenue Service Double Taxation Income Taxes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

The Potential Tax Impact of Foreign Investments

Allen Barron, Inc. on

A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...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

A&O Shearman

U.S.-Chile Income Tax Treaty Enters Into Force

A&O Shearman on

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...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

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

Burr & Forman

Where Did All The "S" Corporations Come From?

Burr & Forman on

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

Troutman Pepper

Addressing the Residency Question - Trust and Estates Update Vol. 2015, Issue 1

Troutman Pepper on

Generally, the first criterion for determining whether an individual is subject to probate or to estate or inheritance tax in a state is the individual’s domicile at the time of his or her death. In an increasingly...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Notice 2013-78: IRS Proposes Revisions to Competent Authority Process"

On November 22, 2013, the IRS issued Notice 2013-78, which contains draft Revenue Procedures applicable to requests for competent authority (CA) assistance. The IRS requested comments by March 10, 2014. The Revenue Procedure...more

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