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GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
Musings on Multinational Tax: What to Expect From GILTI Conscience
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Challenges for Infrastructure Projects in the Current Environment
Podcast: Digital Taxation—Implications for EU Technology Companies
Podcast: Cum-Ex Dividend Trade Investigations
Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more
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
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
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
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
Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more
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
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
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
On July 16 and 17, 2019, the U.S. Senate approved resolutions of ratification of protocols to amend existing income tax treaties between the United States and various countries, including Spain, Japan, and Switzerland. Before...more