On 7 October 2020, the Treasury Department and the Internal Revenue Service (IRS) released final regulations under Code Section 1446(f) (the Final Regulations), which clarify aspects of the withholding requirements with...more
Among the more noteworthy changes made by the Tax Cuts and Jobs Act of 2017 was the creation of Code Section 199A, which grants a deduction to owners of certain pass-through businesses (i.e., sole proprietorships,...more
Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more
On May 10, 2016, India and Mauritius signed a protocol amending the India-Mauritius double income tax treaty that would, among other things, permit India to tax a Mauritian resident on capital gains arising from the sale of...more
Two recent legislative developments, which have largely gone unnoticed, will dramatically raise the stakes for mortgage servicers and originators who file IRS Forms 1098. First, the Trade Preferences Extension Act of 2015,...more
On May 5, 2015, the Internal Revenue Service (“IRS”) released proposed regulations that, if finalized, would provide guidance on qualifying income from minerals and natural resources activities for master limited partnerships...more