Latest Publications

Share:

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

7/7/2014 - Check the Box Rules Cross-Border Foreign Entities IRS Tax Planning

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

6/13/2014 - Controlled Foreign Corporations Corporate Conversions Dividends Foreign Corporations Foreign Investment Jurisdiction Repatriation Shareholders Subpart F Tax Planning Tax Treaty

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

1/29/2014 - Dividends Foreign Nationals Income Taxes Swap Dealers Swaps Tax Evasion

Editorial: How US Cos. Can Reduce Latin American Tax Obligations

Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries. Originally Published in Law360 - October 29,...more

10/30/2013 - Corporate Taxes Foreign Subsidiaries Tax Deferral Tax Liability

Tax Planning For U.S. Companies With Latin American Operations

Pass-through structures - Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more

10/23/2013 - Corporate Taxes Foreign Subsidiaries Income Taxes Tax Planning

5 Results
|
View per page
Page: of 1