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Understanding the Complicated Taxation on Foreign Nongrantor Trusts

March 27, 2024

For many individuals, the U.S. grantor trust taxation is straightforward because it is standard..

topicIcon Tax

Opposition to 15% Minimum Tax in Pillar Two Voiced By U.S. Republicans

October 24, 2023

In September 2023, Republican members of the House Ways and Means Committee met with officials from..

OECD Guidance on Global Tax Deal Gets a Mixed Reaction

March 20, 2023

On Feb. 2, 2023, the Organization for Economic Co-operation and Development/G20 Inclusive Framework..

Coming to a FBAR Filing Near You: Report Your Digital Currency!

May 4, 2021

There will soon be another way you can trip up and have to pay the $10,000 minimum penalty for..

IRS Continues to Refresh and Pursue International Tax Campaigns

April 28, 2021

The IRS’s Large Business & International Division Continues to Refresh and Pursue Issues on its ..

Foreign Nationals Who Will Become US Tax Residents Now Have Greater Certainty on Check-The-Box Planning Prior to US Tax Residency

April 21, 2021

Foreign nationals, such as executives of foreign companies, are transferred to the US for training..

Worldwide Interest Allocation for Foreign Tax Purposes Nixed as Part of American Rescue Plan Act of 2021.

March 8, 2021

If a tree falls in the forest and no one is around to hear it, does it actually make a sound?..

Brutal Results for Foreign Corporation That Failed to File US Tax Returns

March 2, 2021

US Tax Court disallows all deductions for UK company operating in the US on the Outer Continental..

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