| Title |
Author |
Type |
Date |
Words |
| The Sixth Circuit's Whirlpool Opinion - What's the Impact? Ruling disregards regulatory manufacturing exception but preserves right to rely on regulations in applying branch rule. |
Yoder, Lowell; Noren, David; Haxton, Britt |
|
Jul 1, 2022 |
3967 |
| Expatriation from the United States: The Inheritance Tax Under I.R.C. [section]2801. |
Forster, Gary A.; Page, J. Brian |
|
Jul 1, 2022 |
3498 |
| TAX'S DIGITAL LABOR DILEMMA. |
Parsons, Amanda |
|
May 1, 2022 |
28636 |
| Much Ado, but Little New: A Guide to Section 951(a) After Build Back Better, What are the ramifications of Congress' proposal? |
Becker, Adam; Gray, Seth; Stenger, Allen |
Cover story |
Mar 1, 2022 |
10880 |
| Reversing a gap period transaction through late check-the-box election. |
Stenger, Allen; Vukmer, Jane; Grais, Susan Minasian |
|
Jan 1, 2022 |
1464 |
| Automatic procedures to change a CFC's depreciation method. |
Meade, Kathleen; Heroux, Mark |
|
Oct 1, 2021 |
1473 |
| Changes in the U.S. International Tax System Proposed by the Biden Administration. |
Treece, Thomas |
|
May 1, 2021 |
3556 |
| GILTI and Subpart F treatment of distributions of appreciated property. |
Ashman, Joshua; Mintz, Nathan |
|
Feb 1, 2021 |
2561 |
| 'Willful' FBAR penalties upheld: Despite a couple's ignorance of the FBAR filing requirement, their disregard of it was reckless, the Fourth Circuit holds. |
Pirrone, Maria M.; Trainor, Joseph |
|
Feb 1, 2021 |
720 |
| NOL Carrybacks Under the CARES Act: Why it's important to accelerate or otherwise maximize losses in 2020. |
Collins, Bryan P.; Peck, David; Singer, Jay M. |
|
Jan 1, 2021 |
3471 |
| Nonwillful penalties are assessed per FBAR form, not per account: The holding by a district court in the Fifth Circuit conflicts with a case moving through the Ninth Circuit. |
Bonner, Paul |
|
Oct 1, 2020 |
1038 |
| Foreign income taxes deemed paid and the PTEP rules. |
Heroux, Mark |
|
Oct 1, 2020 |
1134 |
| IRS grants relief for COVID-19 disruptions on tax residency: Time rules are eased for the substantial presence test for foreign citizens in the US and the foreign earned income exclusion for US citizens abroad. |
Strausfeld, Dave |
|
May 1, 2020 |
818 |
| Failure to file FBAR is not due to reasonable cause: A taxpayer is subject to civil penalties for nonwillful failure, a court holds. |
Aquilio, Mark |
|
Apr 1, 2020 |
772 |
| The New Exemption from Required Information Reporting: Revenue Procedure 2020-17 Provides Relief for Certain Tax-Favored Foreign Trusts. |
Bahnsen, Nicholas S. |
Column |
Apr 1, 2020 |
1266 |
| CFC downward attributions get safe harbors: Reporting of Subpart F and GILTI inclusions may rely on 'alternate information'. |
Bonner, Paul |
|
Jan 1, 2020 |
756 |
| TEl Files Comments on the Proposed GILTI High-Tax Exception. |
|
|
Jan 1, 2020 |
1117 |
| Foreign-derived intangible income guidance addresses many open questions. |
Camillo, Jay; Chavis, Jillian; Karnis, Daniel; Marrs, Peter |
|
Aug 1, 2019 |
7248 |
| TEI Submits Comments Regarding FDII and GILTI Deductions. |
|
|
Jul 1, 2019 |
4467 |
| States' treatment of GILTI and FDII: The good, the bad, and the ugly. |
Stanton, Catherine; Cosmo, Vito A., Jr.; Holm, Bryan |
|
Jun 1, 2019 |
2015 |
| True, Correct, and Complete: On-time Filing of State and Local Tax Returns Without Clear, Consistent, or Practical Guidance; In a GILTI world, taxpayers need to make their way without a compass. |
Friedman, Jeffrey; Betor, Todd; Hilkin, Michael |
Cover story |
May 1, 2019 |
3092 |
| GILTI: "MADE IN AMERICA" FOR EUROPEAN TAX UNILATERAL MEASURES & COOPERATIVE SURPLUS IN THE INTERNATIONAL TAX COMPETITION GAME. |
Better, G. Charles |
|
Mar 22, 2019 |
18590 |
| Understanding FBAR Disclosure Responsibilities: When Must an Entity or Connected Individual File? |
Weinstock, Ian |
Column |
Mar 1, 2019 |
2471 |
| GILTI, FDII, and FTC Guidance and International Tax Planning: How to decipher this complex stew, replete with interesting ingredients. |
Varma, Amanda |
|
Mar 1, 2019 |
4288 |
| TEI Submits Comments to the Treasury and IRS Regarding Proposed GILTI Regulations. |
|
|
Mar 1, 2019 |
3722 |
| Varian Medical Systems and Forte International Tax Tackle GILTI/FDII and Foreign Tax Credits. |
Gasbarra, Mark; Pollard, Brian |
|
Mar 1, 2019 |
991 |
| The New Normal for International Tax: Finding the Right Tools to Answer the TCJA's Biggest Challenges. |
Chung, Don; Lysenko, Jonathan |
|
Mar 1, 2019 |
958 |
| Understanding the FDII deduction: C corporations with foreign-derived intangible income can benefit from a 37.5% deduction. |
Karnis, Daniel |
|
Feb 1, 2019 |
2541 |
| Should Companies Plan Into Subpart F Following the TCJA? |
Silbering-Meyer, Jessica |
|
Jan 1, 2019 |
1585 |
| The TCJA and foreign real property taxes. |
Yule, Roger J. |
|
Dec 1, 2018 |
1171 |
| Schoolteacher's failure to file FBAR results in $800,000 penalty: The Court of Federal Claims holds that actions and failure to inquire into reporting requirements for a foreign account by a taxpayer who had made a 'quiet disclosure' showed willfulness. |
Aquilio, Mark |
|
Dec 1, 2018 |
972 |
| FBAR Filing for Non-U.S. Citizens. |
Lin, Wilda |
Column |
Oct 1, 2018 |
955 |
| FROM SWITZERLAND WITH LOVE: SURREY'S PAPERS AND THE ORIGINAL INTENT(S) OF SUBPART-F. |
Fishbien, Nir |
|
Sep 22, 2018 |
26243 |
| A QUICK AND EASY GUIDE TO THE NEW FDII, GILTI, AND 100 PERCENT FOREIGN DRD INTERNATIONAL TAX PROVISIONS OF THE 2017 TAX CUTS AND JOBS ACT. |
Burnette-McGrath, Madeleine; DuFresne, Sarah; Muldrew-Mason, Monique; Weaver, Kaden; Brown, Carter; |
|
Sep 22, 2018 |
7999 |
| The new GILT and repatriation taxes: Issues for flowthroughs. |
Lady, Todd C. |
|
Jun 1, 2018 |
6350 |
| First Look at the Tax Cuts and Jobs Act: Questions and Answers about International Taxation. |
Siegfried, Chaya; Kess, Sidney |
|
May 1, 2018 |
1987 |
| Post-Mortem Considerations with Foreign Grantor Trusts After H.R. 1, Tax Cuts and Jobs Acts. |
Rosenberg, Todd; Snyder, Scott |
|
Mar 1, 2018 |
5791 |
| Transnationl tax information reporting: A guide for the perplexed. |
Zimmerman, John C. |
|
Mar 1, 2018 |
10930 |
| Tax-Efficient Supply Chain in Shadow of Tax Reform: GILTI, FDII, and BEAT: they're not just acronyms - they require reassessing tax consequences of existing supply chain structures. |
Spinowitz, Moshe |
Cover story |
Mar 1, 2018 |
3309 |
| Using Income Tax Treaties to Convert Taxable Income Into Nontaxable Distributions. |
Rubinger, Jeffrey L.; LePree, Summer Ayers |
|
Jan 1, 2018 |
3994 |
| Reporting foreign trust and estate distributions to U.S. beneficiaries. |
McNamara, Lawrence H., Jr. |
|
Oct 1, 2017 |
12652 |
| Beyond The Reach: Understanding When a Civilian Contractor's Income is Excluded From Federal Taxation Due to Residing Abroad. |
Dulaney, David; Goodell, John |
|
Sep 1, 2017 |
1349 |
| Former Marine not entitled to exclude foreign earned income: the Tax Court holds the taxpayer's election was untimely. |
Aquilio, Mark |
|
Aug 1, 2017 |
670 |
| Cleansing the PFIC taint: planning and pitfalls. |
Barragato, Charles A. |
|
Jun 1, 2017 |
3498 |
| New reporting requirements for foreign-owned U.S. disregarded entities. |
Hayes, Brian |
|
Apr 1, 2017 |
771 |
| Citizens abroad and social cohesion at home: Refocusing a cross-border tax policy debate. |
Kirsch, Michael S. |
|
Mar 22, 2017 |
24219 |
| Sec. 901(m) temporary regulations apply to covered asset acquisitions. |
Schreiber, Sally P. |
|
Mar 1, 2017 |
769 |
| An update on foreign financial account reporting. |
Holloway, Susanne; Schuldt, Michael A. |
Cover story |
Dec 1, 2016 |
6850 |
| Form 5471 substantial compliance: what does it mean and why is it critical? |
Pasmanik, Philip T. |
|
Jun 1, 2016 |
2459 |
| Water's-edge election: effectively connected income and the 20% rule in California. |
Berkness, Chris; McKinley, Estrilla A.; Yoak, John |
|
May 1, 2016 |
1416 |
| Ohio Supreme Court rules in favor of nonresident athletes against City of Cleveland. |
Speece, Gregory; Walsh, Patrick; Prengler, Hannah M. |
|
Aug 1, 2015 |
1240 |
| Defining "withholding agent": when "everyone" is both too much and not enough. |
Young, Jason |
|
Jul 1, 2015 |
1192 |
| IRS to limit refunds and credits of foreign withholding payments: refunds of tax withheld under Chapters 3 and 4 will be limited to the amounts actually deposited. |
Schreiber, Sally P. |
|
Jul 1, 2015 |
536 |
| U.S. abode binds Russian-employed taxpayer: a taxpayer's strong ties to the United States led to denial of the foreign earned income exclusion despite his spending half his time living and working overseas. |
Pirrone, Maria M. |
|
Jun 1, 2015 |
583 |
| FATCA: a new world of terminology and compliance. |
Pasmanik, Philip; Stratos, Peter |
Cover story |
May 1, 2015 |
6691 |
| FIRPTA rules impact U.S. real estate transactions. |
Hobbs, Jonathan |
|
Apr 1, 2015 |
2473 |
| Final rules govern reporting of specified foreign financial assets: the regulations provide an exception for dual-resident taxpayers taxed as residents of a treaty partner country; IRS requests comments on virtual currency. |
Schreiber, Sally P. |
|
Mar 1, 2015 |
692 |
| IRS offers new options for taxpayers who failed to file international information returns. |
Boyle, Brandon; Trivedi, Shamik |
|
Feb 1, 2015 |
958 |
| The tip of the iceberg: professional liability claims and international taxation. |
Rood, Deborah K. |
|
Oct 1, 2014 |
1105 |
| Understanding your clients' FBAR filing obligations and getting them in compliance. |
Silverstein, Joshua |
|
Jul 1, 2014 |
1485 |
| The creditability of foreign taxes: form vs. substance. |
Wilkinson, Brett R.; Wilkinson, Katherine |
|
Jan 1, 2014 |
4436 |
| FBAR reporting considerations. |
Mahany, Brian |
|
Dec 1, 2013 |
967 |
| American depositary receipts are U.S.-source income subject to withholding. |
Chang, Anne |
|
Nov 1, 2013 |
1672 |
| CFC's software leasing income determined to be foreign personal holding company income. |
Chang, Anne |
|
Nov 1, 2013 |
1595 |
| Reporting foreign investments and activities: requirements and penalties for foreign and U.S. taxpayers. |
Leibowicz, Barry |
|
Jul 1, 2013 |
6892 |
| Sec. 901(m): potential trap for partnership transactions. |
Dokko, Sean; Roth, William F., III; Pedersen, Robert C. |
|
May 1, 2013 |
1772 |
| U.S. withholding tax requirements on payments to nonresidents and foreign entities. |
Weber, Mindy Tyson |
|
Apr 1, 2013 |
2401 |
| The basic framework of cross-border taxation. |
Nevius, Alistair M. |
|
Mar 1, 2013 |
578 |
| Cross-border taxation. |
Leibowicz, Barry |
|
Mar 1, 2013 |
5727 |
| Potential U.S. tax consequences of using foreign sales or manufacturing branches. |
Hedgpeth, Todd W.; Reminick, Holtz Rubenstein |
|
Oct 1, 2012 |
2863 |
| QEF elections under PFIC rules. |
Usher, Scott F.; Pitner, Diana L.; Martin, Bader |
|
Oct 1, 2012 |
980 |
| Taxation of non-resident entertainers and sportsmen: the United Kingdom's definition of performance income and how it ought to be measured. |
Simpson, Alan |
|
Sep 22, 2012 |
11195 |
| IRS issues regs. on sec. 7874 expatriated entities. |
Nevius, Alistair M. |
|
Aug 1, 2012 |
660 |
| IC-DISC offers tax advantages for closely held export companies. |
Thomas, Mary K. |
|
Aug 1, 2012 |
1160 |
| The end of taxation without end: a new tax regime for U.S. expatriates. |
Schneider, Bernard |
|
Jun 22, 2012 |
19192 |
| The end of taxation without end: a new tax regime for U.S. expatriates. |
Schneider, Bernard |
|
Jun 22, 2012 |
15295 |
| IRS withholding tax enforcement: dropping the other shoe? |
Van Leuven, Mary |
|
Jun 1, 2012 |
593 |
| FBAR: handle with care. |
Andreozzi, Randall P.; Hibschweiler, Arlene M. |
|
May 1, 2012 |
9653 |
| Regs, on foreign tax credit splitter arrangements. |
Nevius, Alistair M. |
|
Apr 1, 2012 |
694 |
| Global taxation of cross-border e-commerce income. |
Azam, Rifat |
|
Mar 22, 2012 |
24040 |
| New reporting for specified foreign financial assets. |
Chambers, Valrie |
|
Jan 1, 2012 |
1415 |
| Are hedge funds and private equity funds foreign financial accounts? |
Wong, Alan |
|
Oct 1, 2011 |
1062 |
| Form 1042-S penalties. |
Mahoney, Nicole L. |
|
Sep 1, 2011 |
1608 |
| Tax trends: Tax Court determines character, source of golfer's worldwide endorsement income. |
Nitti, Tony |
|
Sep 1, 2011 |
3584 |
| Delinquent U.S. foreign information returns: is filing under the 2011 OVDI appropriate? |
Bakale, Anthony S. |
|
Aug 1, 2011 |
1201 |
| Deferred taxes on foreign earnings: a road map. |
Abahoonie, Edward J.; Alfonso, Leah N. |
|
Jul 1, 2011 |
2594 |
| Foreign Account Tax Compliance Act. |
|
|
Nov 1, 2010 |
6546 |
| Congress votes to limit use of foreign tax credits. |
Nevius, Alistair M. |
|
Oct 1, 2010 |
332 |
| Uncovering the covered asset acquisition rules. |
Kaplan, Joshua S.; Farrell, Jeffrey W.; Shein, Caren S. |
|
Sep 1, 2010 |
10748 |
| Investing in Canada through an LLC. |
Bakale, Anthony S. |
|
Aug 1, 2010 |
3741 |
| Tax claims in transnational insolvencies: a "revenue rule-approach". |
Weiss, Jonathan M. |
|
Jun 22, 2010 |
28474 |
| Extraterritorial income benefits may still be alive. |
Boyd, Chad; Kaplan, Josh; Bracuti, Guy A. |
|
Jun 1, 2010 |
1863 |
| The software regulations and subpart F. |
Klahsen, Rick |
|
Apr 1, 2010 |
2233 |
| Profile of multinational businesses with inbound investments. |
Godfrey, Howard; Wiggins, Casper |
|
Mar 1, 2010 |
6051 |
| U.S.-source FDAP income compliance designated as Tier 1 issue. |
Faulk, Daniel |
|
Nov 1, 2009 |
1309 |
| Taking your business global? 10 important indirect tax issues to consider. |
Walsh, Chris |
|
Nov 1, 2009 |
4961 |
| International taxation: a guide for academics abroad. |
Dhanda, Michelle |
|
Sep 22, 2009 |
14628 |
| Adopting or changing a foreign corporation's accounting method. |
Hui, Irene Pik-Wah |
|
Jul 1, 2009 |
1011 |
| Expatriation and the new mark-to-market rules. |
Fava, Karl L. |
|
Jul 1, 2009 |
5724 |
| Tax treaty net basis elections. |
Lan, David; Karges, Martin |
|
May 1, 2009 |
1667 |
| New subpart F Regs. address manufacturing exception and branch rules. |
Hawkins, Bert J.; Koval, Cari A. |
|
Apr 1, 2009 |
2280 |
| Comments on proposed contract manufacturing regulations. |
Ugai, Brian C. |
|
Mar 1, 2009 |
3353 |
| CFC credit rules eased. |
Sherr, Eileen Reichenberg |
|
Jan 1, 2009 |
306 |
| The application and analysis of the new proposed contract manufacturing regulations. |
Hadjilogiou, Steven |
|
Jan 1, 2009 |
3731 |
| Withholding from foreign payments: IRM section offers insight. |
Pasmanik, Philip T. |
|
Dec 1, 2008 |
745 |
| Automatic penalties for late forms 5471 and related forms. |
Sherr, Eileen Reichenberg |
|
Nov 1, 2008 |
409 |
| New Temp. Regs. under Sec. 905(c). |
Dash, Roopesh; Gupta, Sima; Landreneau, Frank |
|
Nov 1, 2008 |
2427 |
| Selected provisions of the Fifth Protocol to the U.S.-Canada Income Tax Treaty. |
Carsalade, Rafael |
|
Nov 1, 2008 |
1635 |
| Adapting to the United Kingdom's new remittance basis rules. |
Whittall, Robert E. |
|
Aug 1, 2008 |
2407 |
| Virtual manufacturing and the proposed contract manufacturing regulations. |
Granwell, Alan W.; Andreoli, Brian |
|
Jul 1, 2008 |
7624 |
| TEI's comments on proposed contract manufacturing regulations. |
|
|
Jul 1, 2008 |
7580 |
| Foreign tax credits: reducing eight categories to two. |
Jones, Don |
|
May 1, 2008 |
1236 |
| Tax Court holds - repeatedly - that Antarctica is not a foreign country. |
Nevius, Alistair M. |
|
Apr 1, 2008 |
610 |
| Form 1042 information reporting requirements. |
Pasmanik, Philip T.; Verzi, Robert A. |
|
Apr 1, 2008 |
1916 |
| Commentary on the Canada-U.S. Tax Treaty's Fifth Protocol. |
Sardella, Joseph |
|
Mar 1, 2008 |
3103 |
| The quest to tax interest income in a global economy: stages in the development of international income taxation. |
Benshalom, llan |
|
Jan 1, 2008 |
32052 |
| International tax neutrality: reconsiderations. |
Shaheen, Fadi |
|
Jun 22, 2007 |
13752 |
| Proposed "technical taxpayer" regulations shut down guardian and reverse hybrid structures. |
Rubinger, Jeffrey L. |
|
Feb 1, 2007 |
4374 |
| Sourcing the "unsourceable": the cost sharing regulations and the sourcing of affiliated intangible-related transactions. |
Benshalom, Ilan |
|
Jan 1, 2007 |
31044 |
| New rules for individuals working abroad: changes to income and housing exclusions. |
Laffie, Lesli S. |
|
Dec 1, 2006 |
524 |
| New subpart F lookthrough rules. |
Morrison, Richard |
|
Nov 1, 2006 |
1000 |
| The increased costs of working abroad. |
Carsalade, Rafael |
|
Nov 1, 2006 |
546 |
| Interest owed to a related foreign entity. |
Brown, Michael H. |
|
Oct 1, 2006 |
418 |
| Is Antarctica a foreign country? |
Reichert, Charles J. |
|
Jun 1, 2006 |
536 |
| TEI urges Canadian government to abandon proposed legislation relating to foreign investment entities. |
|
|
May 1, 2006 |
8746 |
| Availability of the foreign earned income exclusion, FTCs and combat pay exclusion for U.S. government contractors. |
Ballard, Christine |
|
Apr 1, 2006 |
980 |
| ETI and IC-DISC export tax benefits for government contractors. |
Ballard, Christine |
|
Apr 1, 2006 |
1007 |
| Planning for the currency gap in dispositions of foreign subsidiaries. |
Arndt, Christopher |
|
Apr 1, 2006 |
1217 |
| Treasury department and IRS launch review of cross licensing arrangements: detailed information requested from business community. |
Kawano, Akemi |
|
Mar 1, 2006 |
2173 |
| Canadian liaison meetings top TEI's advocacy agenda: comments also filed on cost-sharing regulations; amicus brief filed in Cuno case. |
|
|
Nov 1, 2005 |
1288 |
| Notice 2005-64 completes the IRS's Section 965 trilogy. |
Stoffregen, Philip A. |
|
Sep 1, 2005 |
9738 |
| Withholding requirements for partnerships with foreign partners. |
Nazir, Sadia |
|
Sep 1, 2005 |
737 |
| Marks & Spencer: EU claims for cross-border loss relief. |
Hare, Jonathan |
|
Jul 1, 2005 |
3184 |
| Reporting and disclosing foreign financial accounts. |
Jacobs, Vernon K. |
|
Jun 1, 2005 |
4235 |
| New rules on FTC allocations. |
Shum, Michael G. |
|
Jun 1, 2005 |
2427 |
| Forms of overseas operations. |
Shum, Michael G. |
|
Apr 1, 2005 |
5524 |
| Forms of overseas operations: this two-part article explores the major characteristics, advantages and disadvantages of the different types of entities for conducting business overseas. |
Shum, Michael G. |
|
Mar 1, 2005 |
3983 |
| AJCA. |
Laffie, Lesli S. |
|
Jan 1, 2005 |
1557 |
| ETI exclusion repeal: transition relief. |
Rollinson, Marjorie A. |
|
Jan 1, 2005 |
370 |
| Qualified dividend income under the 2003 Tax Act: this article discusses the basics of QDI, including corporations eligible to pay QDI and the required stock holding periods. |
Bogos, Nicholas |
|
Nov 1, 2004 |
3772 |
| New treaty with Japan eliminates source-country withholding taxes on royalties. |
Reinstein, Todd B. |
|
Sep 1, 2004 |
415 |
| Tax incentives for exporters. |
Granberg, Michael W. |
|
Sep 1, 2004 |
1503 |
| Statement before Senate Foreign Relations Committee on Dutch and Barbados treaties: September 24, 2004. |
|
|
Sep 1, 2004 |
1300 |
| A guide to foreign corporation E&P. |
Soltis, Sandra |
|
Jun 1, 2004 |
3361 |
| A guide to foreign corporation. |
Soltis, Sandra |
|
May 1, 2004 |
3656 |
| Perpetuation of the foreign earned income exclusion: U.S. international tax policy, political reality, and the necessity of understanding how the two intertwine. |
Sheppard, Hale E. |
|
May 1, 2004 |
16796 |
| Revised Canadian proposals affecting foreign affiliates. |
Slaats, Sandra |
|
Mar 1, 2004 |
4291 |
| TEI comments on repeal of the FSC/ETI provisions and other international and corporate reform and simplification proposals. |
|
|
Mar 1, 2004 |
4197 |
| Prop. regs. on partnership withholding on foreign partners. |
Penick, Barksdale |
|
Jan 1, 2004 |
390 |
| Canada's new foreign investment entity rules. |
Marley, Patrick |
|
Jan 1, 2004 |
8688 |
| Reporting common foreign transactions of U.S. clients. |
Jacobs, Vernon K. |
|
Dec 1, 2003 |
3067 |
| PFIC/CFC overlap: not out of the woods yet. |
Madden, David |
|
Jun 1, 2003 |
1692 |
| Internet transactions and PE issues. |
Nakamoto, Kelly |
|
May 1, 2003 |
2708 |
| Tax trap for second-time U.S. residents. |
Ochsenschlager, Thomas P. |
|
Feb 1, 2003 |
950 |
| CFC's treatment of partnership income. |
Parmegiani, Leo |
|
Nov 1, 2002 |
1376 |
| ETI tax benefit for domestic sales. |
Loftin, Joe |
|
Nov 1, 2002 |
1320 |
| Foreign and tax-exempt partners' tax years. |
Pimenta, Antonio D. |
|
Nov 1, 2002 |
856 |
| Avoiding a nuclear trade war: strategies for retaining tax incentives for U.S. corporations in a post-FSC world. |
Von Hoff, Carrie Anne |
|
Oct 1, 2002 |
17166 |
| Deducting interest owing to a related foreign person. (Interest Income & Expense). |
Granberg, Michael W. |
|
Sep 1, 2002 |
1248 |
| Conflict over PTI. |
Smith, Annette B. |
|
Jul 1, 2002 |
925 |
| PFICs: applying the subsidiary look-through rules to intercompany transactions. |
Laudeman, Robert |
|
Jun 1, 2002 |
2009 |
| U.S. income taxation of foreign nationals; income source could be a problem for nonresident aliens. |
Fiore, Nicholas J. |
|
Apr 1, 2002 |
621 |
| Guide to U.S. income taxation of foreign nationals. |
Amitrano, Anthony G., Jr. |
|
Apr 1, 2002 |
4128 |
| Elections pursuant to FSC Repeal and Extraterritorial Income Exclusion Act of 2000. |
O'Connell, Frank J., Jr. |
|
Sep 1, 2001 |
1088 |
| New Opportunities to Exclude Foreign Income. |
Bakale, Anthony |
|
Aug 1, 2001 |
1710 |
| IRS warns against frivolous filing positions that rely on foreign-based-income argument. |
Fiore, Nicholas J. |
|
Aug 1, 2001 |
533 |
| Proposed source rules for space, ocean, and communications income sweep broadly, set high hurdles for taxpayers. |
Maruca, Samuel M. |
|
Mar 1, 2001 |
4972 |
| Treasury's long-awaited Subpart F study breaks no new ground, touts ending deferral. |
Garrett-Nelson, LaBrenda |
|
Jan 1, 2001 |
5678 |
| U.S.-Canada income tax treaty requires income of U.S. branch to be determined under facts and circumstances. |
Renfroe, Diane L. |
|
Nov 1, 1997 |
719 |
| Sourcing of losses on foreign subsidiary stock sales. |
Goodman, Mark E. |
|
Sep 1, 1997 |
1154 |
| Proposed regulations affect form of funding international operations. |
Kingsley, William P. |
|
May 1, 1997 |
743 |
| Trade name licensing in foreign markets. |
Sani, Elizabeth |
|
Apr 1, 1997 |
1295 |
| Sourcing of capital losses under Sections 861, 865, and 904: October 17, 1996. |
|
|
Nov 1, 1996 |
2017 |
