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U.S. expatriates should read IRS Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad. This is a beneficial article published by the agency itself, detailing the unique and specific tax reporting...more
When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more
Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary fails to cash a distribution check and a replacement check is issued. As discussed...more
The IRS has released Revenue Ruling 2025-15, which clarifies the federal tax withholding and reporting responsibilities of retirement plan administrators when a distribution check is issued but remains uncashed and a...more
On July 16, 2025, the IRS issued guidance regarding uncashed retirement plan distribution checks and subsequent replacement checks. Revenue Ruling 2025-15 clarifies that the fact that a distribution check remains...more
The Massachusetts Department of Revenue (“DOR”) has proposed a new regulation, 830 CMR 62B.2.4, which introduces a significant change to the taxation of real estate transactions within the Commonwealth by non-resident...more
The One Big Beautiful Bill Act (the “Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more
1. Types of Business Entities - Italian law provides multiple forms of organizational structures to do business in Italy. They differ from one another due to the extent of liability undertaken by its members. In...more
The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...more
On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more
After years of negotiation and technical debate, the European Union’s Faster and Safer Tax Relief of Excess Withholding Taxes Directive (“FASTER Directive”)—aimed at streamlining and harmonizing withholding tax (WHT) relief...more
On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more
Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more
In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
a) Types of business entities in Kenya - Kenya has 5 main types of business entities that is, sole proprietorships, partnerships, limited liability partnerships, companies, non-governmental organizations and trusts. A...more
1. Types of Business Entities - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business --- Business entities available for doing business in Japan - 1.1.1...more
Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more
1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother...more
Kazakhstan will soon adopt a new tax code, with the bill currently in Parliament. It is expected that the new tax code will be adopted this year and come into force beginning 2026. This LawFlash summarizes the general...more
Transactions involving the disposition of a U.S. real property interest (“USRPI”) by a foreign person (i.e., a nonresident alien individual or foreign entity, the seller) are subject to the Foreign Investment in Real Property...more
[co-author: Mourice Okon] a) Types of business entities in Kenya - Kenya has 5 main types of business entities that is, sole proprietorships, partnerships, limited liability partnerships, companies, non-governmental...more
1. Types of Business Entities - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business --- Business entities available for doing business in Japan - 1.1.1 ...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER UKRAINIAN LAW - І. Types and specifics of real estate in Ukraine - The main types of real estate in Ukraine are the following: • plots of land; • other objects that...more