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Internal Revenue Code (IRC) NIIT

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XV – Being an...

Foster Garvey PC on

In this Part XV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a potential advantage that the S corporation has over the C corporation. The Patient Protection and Affordable Care...more

Fenwick & West LLP

Bruyea v. United States - Latest Foreign Tax Credit Case on the NIIT Sheds Important Light on Treaty Double Tax Articles

Fenwick & West LLP on

Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more

Allen Barron, Inc.

A New Wave of U.S. Expatriate Income Tax Refund Applications?...

Allen Barron, Inc. on

Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more

McDermott Will & Emery

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

McDermott Will & Emery on

In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more

Gray Reed

Taxation of Digital Collectibles: Sports, CryptoPunks and CryptoKitties, Oh My!

Gray Reed on

What do professional athletes, punk artwork and digital kittens have in common?  They are all part of the expansion of valuable collectible assets using cryptocurrency and blockchain technology.  You can collect digital items...more

Blank Rome LLP

Application of Net Investment Income Tax to Section 453A Interest

Blank Rome LLP on

Although the Internal Revenue Service (IRS) has not directly addressed this matter, interest accruing from installment agreements sales under Internal Revenue Code (IRC) section 453A is likely not included in net investment...more

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