What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more
Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings - Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...more
Highlights - • In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more
La "Ley de Reducción de impuestos y empleos" (la "Ley") tiene el propósito declarado de que los EE.UU. se convierta a un sistema de impuestos “territorial". Antes de que se aprobara la Ley, la mayoría de las empresas de los...more
The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system. Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore. In the...more
IRS Issues Proposed Regulations Providing Guidance On The Tax Qualification Of Mutual Funds - On September 27, 2016, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) that provide...more
AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more