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Publications by Elizabeth V. Zanet

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Publications

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Tax Basics of Intellectual Property

Published in Landslide Volume 10 Issue 6, © 2018 by the American Bar Association.

A New Tax Regime for CFCs: Who Is GILTI?

Published by the Civil Research Institute in the Journal of Taxation and Regulation of Financial Institutions, vol. 31, no. 03 (Spring 2018): pp. 17-28.

US Tax Reforms - Anti-Abuse Regime for CFCs

Published on Out-law.com (March 2018).

Tax 101: Taxation of Intellectual Property—Selected Tax Issues Involving Corporations and Partnerships

Published in The Licensing Journal vol. 37, no. 9 (October 2017): pp. 11-18.

Good News for REITs Investing in Non-US Real Estate

Published in the GGi Insider, No. 88, March 2017 (p. 44).

presentations

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Inside the Global Tax Practice: A Seminar on U.S. International Tax Planning
Video | Tax Planning for Brexit & Beyond
Tax Planning for Brexit & Beyond

articles from insights
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I.R.S. Adds New Issues of Focus for Cross-Border Audits
A Deep Dive into G.I.L.T.I. Guidance
Transition Tax – Proposed Regulations Are Here
Tax Considerations of I.P. When Expanding a Business Offshore
Inbound Acquisition Due Diligence Under U.S. Tax Reform
I.R.S. Announces Six Compliance Campaign
I.R.S. Notice 2018-28 Announces Code §163(j) Regulations on Interest Payment Deductions
Code §962 Election Offers Benefits Under U.S. Tax Reform
New York Resisting S.A.L.T. Cap Under Federal Tax Reform
Changes to C.F.C. Rules – More C.F.C.’s, More U.S. Shareholders, More Attribution, More Compliance
A New Tax Regime for C.F.C.’s: Who Is G.I.L.T.I.?
Anti-Inversion Rules Are Not Just for Mega-Mergers – Private Client Advisors Take Note
When Does an Aged Account Receivable Give Rise to a Deemed Repatriation?
Tax 101: Deemed Annual Royalty on Outbound Transfers of I.P. to Foreign Corporations
Foreign Partner Not Subject to U.S. Tax on Gain from Redemption of U.S. Partnership Interest
Tax 101: Taxation of Intellectual Property – Selected Issues Involving Corporations and Partnerships
Tax 101: Taxation of Intellectual Property – The Basics
How to Calculate Gain or Loss on Payables & Receivables Denominated in Nonfunctional Currency
A Look at the House G.O.P.’s “Destination-Based Cash Flow with Border Adjustment”
I.R.S. Rules Subpart F & P.F.I.C. Income Inclusions Are R.E.I.T. Qualifying Income
Trump and the Republican-Led Congress Seek Overhaul of International Tax Rules
The 2016 U.S. Model Income Tax Treaty
Regulations Would Address Foreign Tax Credit Planning for E.U. State Aid Adjustments
I.R.S. Advises Scrutiny Required for Partner’s Foreign Earned Income
German-Trained Lawyer Could Not Deduct U.S. Educational Expenses
Crowdfunding: A Popular Way to Invest, but Watch Out for Taxes
Income Tax Treaties v. Domestic Law: An International Look at the Current Score
Insights Vol. 3 No. 5: Updates & Other Tidbits
What Is a Corporate Business Purpose for a Tax-Free Corporate Division?
2016 Model Treaty – B.E.P.S. and Expatriated Entities