In this article: - Income Tax - Other Foreign Taxes -- Vat And Social Security Taxes - Foreign Tax Credit Planning - U.S. Withholding Obligations - Use Of Loan Out Company -...more
When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more
On March 28, 2013, the New York State Legislature passed budget legislation (S.2609D/A.3009D) that replaces the existing New York State and City related - party royalty add - back requirements with provisions based on the...more
On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more
Since Section 1(h)(11) was enacted as part of the Jobs and Growth Tax Relief Reconciliation Act of 2003, questions have been raised on exactly how to interpret the section's legislative history. Under this provision, a...more
Okay, let’s admit it—plenty of us had absolutely no interest whatsoever in becoming tax specialists when we started law school. And so here we are, all these years later, serving as employment counsel to our corporate...more
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