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Tax Liability › Internal Revenue Code (IRC) › Foreign Investment

Orrick, Herrington & Sutcliffe LLP

UK Founder Series: Flip Back from the U.S. – Key U.S. Tax Considerations

Orrick, Herrington & Sutcliffe LLP on

Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Bilzin Sumberg

Proposed Regulations May Affect Taxation of Foreign Investors in REITs

Bilzin Sumberg on

On December 29, 2022 the IRS and the Treasury Department issued a notice of proposed rulemaking (REG-100442-22) (the “Proposed Regulations”) that, among other things, affects the determination when Real Estate Investment...more

Freeman Law

The Section 965 Transition Tax And IRS Audits

Freeman Law on

Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more

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