News & Analysis as of September 21, 2024

Tax Treaty

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations for Some US Taxpayers

Katten Muchin Rosenman LLP on 5/15/2024

It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on 1/4/2024

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

U.S.-Chile Income Tax Treaty Enters Into Force

A&O Shearman on 12/28/2023

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more

IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters

McDermott Will & Emery on 7/25/2023

There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more

Reviewing a Foreign Legal Structure

Freeman Law on 1/25/2023

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Tax Court in Brief | Smith v. Comm’r | Closing Agreement and Malfeasance of Fact

Freeman Law on 1/3/2023

Short Summary: The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more

International Tax Concepts: Tax Residency Status

Freeman Law on 10/3/2022

U.S. Tax Residency Status - As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy...more

Weekly IRS Roundup May 31 – June 3, 2022

McDermott Will & Emery on 6/8/2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 31, 2022 – June 3, 2022... May 31, 2022: The IRS issued a press release, reminding...more

Tax Treaties and Exempt Income

Freeman Law on 4/12/2022

Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more

Navigating the Branch Profits Tax

Freeman Law on 4/1/2022

The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more

Withholding Agents and FDAP Income

Freeman Law on 3/31/2022

Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more

FDAP Income

Freeman Law on 3/30/2022

The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more

Tax Treaty-Based Return Reporting Disclosures

Freeman Law on 2/24/2022

A taxpayer taking a treaty-based return position is generally required to disclose that position, unless an exception applies. A treaty-based return position is a tax reporting position, maintaining that a U.S. tax treaty...more

IRS Targets Participants in Malta Pension Plan Transactions

Freeman Law on 1/13/2022

This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more

The IRS’s Dirty Dozen Tax Schemes—Installment Four

Freeman Law on 7/27/2021

The IRS recently concluded its 2021 four-part series of the “Dirty Dozen” tax-related scams. The fourth installment focuses on what the Service refers to as “schemes peddled by tax promoters, including syndicated...more

Weekly IRS Roundup May 31 – June 4, 2021

McDermott Will & Emery on 6/8/2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 31, 2021 – June 4, 2021... June 1, 2021: The IRS issued a news release, soliciting...more

Will a U.S. Tax Treaty Apply to a U.S. State’s-Imposed Tax?

Freeman Law on 6/2/2021

Two countries form a treaty under the general principles of contract law. A fundamental aspect of contract law requires a meeting of the minds – a shared understanding of the agreed terms. Accordingly, unless expressly...more

The Tax Court in Brief - January 2021

Freeman Law on 1/27/2021

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

THE WONDER YEARS WEBINAR

Gerald Nowotny - Law Office of Gerald R.... on 10/7/2020

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Stranded Canadians Taxed in the Time of Covid-19

Dorsey & Whitney LLP on 3/27/2020

As Covid-19 continues to spread, many countries, including the United States and Canada, are increasingly closing their borders in an attempt to slow the rate of infection. This precaution may, however, have unintended tax...more

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

Foodman CPAs & Advisors on 10/11/2019

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

How to determine an Individual’s Residency for Tax Treaty Purposes?

Foodman CPAs & Advisors on 12/7/2018

The guidelines for determining an Individual’s tax residency are as follows: - An Individual Taxpayer is a resident based on the laws of one treaty-partner country and is considered to be a resident of that country for...more

5 Common Tax Misconceptions Facing U.S. Persons Living Outside the U.S.

Butler Snow LLP on 7/6/2018

Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more

"Notice 2013-78: IRS Proposes Revisions to Competent Authority Process"

Skadden, Arps, Slate, Meagher & Flom LLP on 1/10/2014

On November 22, 2013, the IRS issued Notice 2013-78, which contains draft Revenue Procedures applicable to requests for competent authority (CA) assistance. The IRS requested comments by March 10, 2014. The Revenue Procedure...more

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