The U.S. Supreme Court has affirmed the Ninth Circuit's decision in Moore v. United States, upholding the constitutionality of the mandatory repatriation tax enacted in 2017....more
New IRS guidance issued on qualified foreign pension fund exception.
On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more
6/13/2019
/ Anti-Abuse Rule ,
FATCA ,
FIRPTA ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
Pension Funds ,
Proposed Regulation
Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more
5/2/2019
/ Blockchain ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Financial Transactions ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Planning ,
Token Sales ,
Virtual Currency
On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more