Expiring ITINS
Individual Taxpayer Identification Numbers (ITINs) are tax processing numbers, issued by the U.S. Internal Revenue Service (IRS),…
Volume 1 No. 3
China Issues Clearer Guidance For “Beneficial Owners” by Yang Sun and Xiuning Hao (China) The Cristiano Ronaldo…
Volume 1 No. 2
Transfer Pricing Post Chevron by Gil Levy (Australia) Tax Developments in Argentina by Javier Canosa (Argentina) New…
Safe Income May Vary Within Shares of the Same Class
The anti-surplus-stripping provision in subsection 55(2), which can recharacterize a dividend as a capital gain, is not of…
The U.S. Repatriation Tax – IRC §965: Proposed Regulations Issued
On August 3, 2018 the IRS issued “final” proposed regulations implementing new section 965 of the Internal…
FBAR Penalties – the Court Speaks (for now)
The Internal Revenue Service was handed a defeat with respect to its ability to assess some penalties…
IRS Service Offerings – Available to Some, Not All
U.S. citizens abroad are burdened with the same federal tax compliance obligations as U.S. residents. In fact,…
U.S. Sales Tax – Update: The Streamlined Sales and Use Tax Agreement (SSUTA)
In light of the United States Supreme Court South Dakota v. Wayfair et al decision, 585 U.S.__(2018) (see U.S. Tax…
The U.S. Repatriation Tax – IRS issues further guidance
On June 4, 2018 the IRS issued News Release IR-2018-131. In this release the IRS address some…
New IRS Compliance Programs
On July 2nd, the IRS Large Business and International division (LB&I) announced five new additional compliance programs. …
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