This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more
It is well established, under common law principles applicable in the Cayman Islands and the British Virgin Islands that claims for payment of foreign tax liabilities, or claims for the enforcement of foreign judgments for...more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more
In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...more
IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN. What happens when settling parties agree that the defendant will...more