International Tax Articles
Posted by Mark Janulewicz on August 10, 2020
On July 28, 2020, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) released final regulations under Section 163(j).
Posted by Amanda Mooney on April 24, 2020
At the request of concerned countries, the OECD Secretariat issued the guidance based on a careful analysis of the international tax treaty rules. The analysis addresses concerns as a result of the novel coronavirus (COVID-19) pandemic related to the creation of a permanent establishment (PE), the residence status of a company (place of effective management), cross border workers, and a change to the residence status of individuals.
Posted by Mark Janulewicz on April 21, 2020
Volatility created by the COVID-19 pandemic has had an immediate impact on many U.S. taxpayers conducting business abroad. Due to liquidity and cash flow needs, such U.S. taxpayers may need to repatriate cash from their foreign operations. This alert discusses some key international tax issues that taxpayers may need to consider when repatriating cash from their foreign operations.
Posted by Cory Van Deusen V on June 14, 2019
On April 17, 2019, the IRS and Treasury issued its much anticipated second set of proposed regulations under Internal Revenue Code, Section 1400Z-2, Special rules for capital gains invested in opportunity zones.
Posted by Sherry DelleBovi, James Dunn Jr., Michael Grimaldi, Mark Janulewicz, Brian Kern, Michē Needham, David Schlein, Cory Van Deusen V on January 03, 2019
Business tax planning is very complex. Careful planning involves more than just focusing on lowering taxes for the current and future years. How each potential tax saving opportunity affects the entire business must also be considered.
Posted by Cory Van Deusen V on August 14, 2018
The Tax Cuts and Jobs Act makes sweeping changes, but some of the new provisions won't necessarily be relevant to your situation. Here's a quick reference guide to the major changes under the new law to help you understand what's changing.
Posted by David Schlein on August 09, 2018
Do you have long-term capital gains or qualified dividends? If so, there's good news: After the Tax Cuts and Jobs Act (TCJA), you might still qualify for the 0% federal income tax rate on these types of income.
Posted by Mark Stack on June 26, 2018
The new U.S. Supreme Court ruling paves the way for states to require Internet sellers to collect sales tax from consumers — even if they don't have a physical presence in the state.
Posted by David Schlein on June 08, 2018
The tax brackets for long-term capital gains and qualified dividends are changing under the new tax law. For 2018 through 2025, these brackets aren't linked to the ordinary-income tax brackets for individuals.