Bilzin Sumberg - International Taxation

1450 Brickell Avenue 23rd Floor
Miami, Florida 33131-3456, United States

  • 305.374.7580
  • 305.374.7593

IRS Disregards Own Revenue Ruling in Barnes Decision

The Court of Appeals for the Second Circuit recently affirmed the Tax Court’s 2013 decision in Barnes Group, Inc. and Subsidiaries, T.C. Memo 2013-109, in which the Tax Court applied the step transaction doctrine to…more
| Commercial Law & Contracts, International Law & Trade, Science, Computers, & Technology, Taxation

10th Annual University of Florida International Tax Symposium

On Friday, October 31, I will be speaking at the 10th Annual University of Florida International Tax Symposium held at the University of Florida, Levin College of Law in Gainesville, Florida…more
| Taxation

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning…more
| Commercial Law & Contracts, Intellectual Property, International Law & Trade, Taxation

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from…more
| Civil Procedure, Civil Remedies, Insurance, International Law & Trade, Taxation

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated to…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

IRS Taking Closer Look at Section 956 Inclusions

Each “U.S. Shareholder” of a controlled foreign corporation (“CFC”) is required to include in their gross income as a deemed distribution their pro rata share of the amount determined under section 956 for that year (i.e.,…more
| Finance & Banking, International Law & Trade, Taxation

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will…more
| Commercial Law & Contracts, Mergers & Acquisitions, International Law & Trade, Taxation

How Windstream Ruling Will Affect Foreign Taxpayers

In general, a REIT is a special purpose entity for U.S. federal income tax purposes that requires at least 75 percent of the value of the entity’s gross assets to consist of real estate assets, cash, cash items, and governmental…more
| Commercial Law & Contracts, International Law & Trade, Securities Law, Taxation, Real Estate - Commercial

IC-DISC Benefits Enhanced with Foreign Shareholders

Since the reduction in the individual tax rate on qualified dividends in 2004, the Interest Charge Domestic Sales Corporation (“IC-DISC”) has become an attractive vehicle to obtain a tax incentive for exporting U.S.-produced…more
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Taxation

Local Law Shopping Through “Derivative Benefits”

Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g.,…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Inbound U.S. Tax Planning With Inversions

With all of the recent negative publicity focused on the outbound restructuring of U.S. multinationals engaging in so-called “inversion” transactions (see prior blog “Corporate Inversions Showing No Signs of Slowing Down”),…more
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Taxation

Synthetic Investment in U.S. Real Estate by Foreign Investors

According to recent reports, foreign investment in commercial U.S. real estate exceeded $38.7 billion in 2013 - a 40 percent increase over 2012. Leading the way in 2013 were investors from Canada, China, Australia, Germany, and…more
| Finance & Banking, International Law & Trade, Taxation, Real Estate - Commercial

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
| Business Organizations, Commercial Law & Contracts, Immigration Law, International Law & Trade, Taxation

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC is…more
| Commercial Law & Contracts, International Law & Trade, Securities Law, Taxation

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or transfers…more
| Elections & Politics, Mergers & Acquisitions, International Law & Trade, Science, Computers, & Technology, Taxation
Showing 1-15 of 21 Results
|
View per page
Page: of 2
Areas of Practice
  • International Law & Trade
  • Taxation
Locations
Other U.S. Locations
  • Florida
Number of Attorneys

100+ Attorneys

This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.