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Cross-Border Internal Revenue Code (IRC)

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

Holland & Knight LLP on

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Lasher Holzapfel Sperry & Ebberson PLLC

Estate Planning for the Modern Global Family

Estate planning tends to be a topic that overwhelms most people. It can be further complicated for modern-day global families whose lives include international nuances. For example, when one spouse is not a U.S. citizen,...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Fenwick & West LLP

Tax Alert: IRS Untangles Section 163(L) in Cross-Border Hybrid Financing Transaction

Fenwick & West LLP on

“In terrorem” or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in 1997, is no exception, so that even now certain fundamental questions relating...more

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