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Internal Revenue Code (IRC) Foreign Nationals

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Wiley Rein LLP

Bipartisan Lawmakers Propose Amendments to FARA, Tax Law, and Election Laws to Combat Foreign Influence in U.S. Policy

Wiley Rein LLP on

On June 16, 2022, a bipartisan group of lawmakers in the U.S. House of Representatives introduced the Fighting Foreign Influence Act, which would impose a range of new disclosure requirements and limitations on think tanks,...more

Nutter McClennen & Fish LLP

Treasury Issues Final Regulations on Section 721(c) Partnerships

As you probably know, a taxpayer realizes gain when the taxpayer transfers appreciated property in exchange for other property. There are exceptions to this general rule. One of those exceptions is defined in Internal Revenue...more

Foley Hoag LLP - Medicaid and the Law

Why are Medicaid and CHIP enrollment numbers declining?

For much of the past two years, enrollment in the Medicaid and CHIP programs has been declining. In May, 2017, enrollment in both programs was 74.6 million people. As of May of this year, enrollment had declined by 2.5%, to...more

Wilson Sonsini Goodrich & Rosati

Recent Guidance Regarding Withholding on Certain Transfers of Partnership Interests by Non-U.S. Persons

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more

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