Section 6418 of the Internal Revenue Code (as added by the Inflation Reduction Act of 2022) allows an eligible taxpayer that qualifies for certain clean energy tax credits, including investment tax credits and production tax...more
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more
The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more