When a taxpayer receives an information document request (“I.D.R.”) from the I.R.S. for transfer pricing documentation, it should know what to expect: a lengthy, contentious process of documenting and defending its tax position. Pausing to think objectively about the cognitive biases, strengths, and weaknesses underlying a transfer pricing position is an essential step to take before delving into the technical aspects of the examination itself.
Please join Ruchelman P.L.L.C. for an evening sharing experiences and building connections with women in finance and law.
Part two of our series will address recent U.S. tax reform, including these and other key issues: the Dividends Received Deduction, G.I.L.T.I., F.D.I.I., B.E.A.T., and Q.B.I.
The first in a two-part series, this program will address the core concepts of U.S. tax law, including these and other key issues: entity classification rules (classification of foreign entities as corporations, partnerships, and single-member L.L.C.’s for U.S. tax purposes), Controlled Foreign Corporations, Passive Foreign Investment Companies, and distributions from corporations.
Three years have passed since the O.E.C.D./G-20 Base Erosion and Profit Shifting Project identified 15 Actions necessary for preventing loss of tax revenue through abusive, cross-border tax planning. In the interim, countries have taken action to implement these recommendations. Panelists from Brazil, India, the Netherlands, and the U.S. will explain how the B.E.P.S. Actions are applied on the ground in various regions.
While tax reform has changed the landscape, the U.S. remains an appealing place for foreign entrepreneurs. Advisors must be prepared to answer questions when clients plan a move to the U.S.
This CLE/CPE webinar will provide tax professionals guidance on new rules and regulations governing the taxation of foreign source income. The panel will present an in-depth analysis of the expansion of Subpart F, the dividends received deduction ("D.R.D."), tax implications of sales or transfers of foreign corporations by U.S. shareholders, and provide guidance on avoiding pitfalls to ensure tax savings and reporting compliance.
Ruchelman is pleased to lend its support to the 18th Annual Tax Planning Strategies – U.S. and Europe. On April 12, Stanley C. Ruchelman will speak on the Impact of U.S. Tax Reform on International Structures.
Although some Federal priorities change, the I.R.S. continues to focus on offshore bank accounts and the obligation to report foreign assets on the Report of Foreign Bank and Financial Accounts. In this program, Rusudan Shervashidze and Lawrence S. Feld will explore the F.B.A.R. reporting regime and discuss the U.S. government's criminal and civil enforcement efforts.
This program will focus on the critical issues of Eurocentric tax planning in the age of Brexit, B.E.P.S., and emboldened tax authorities. It is presented in conjunction with the Taxation of Business Entities Committee and the European Affairs Committee the New York City Bar Association and the Chartered Insitute of Taxation (CIOT).
Tax reform in the U.S., Brexit in the U.K., and international efforts to fight base erosion and profit shifting are changing the tax landscape. Panelists will discuss how the new environment affects companies engaged in business between the U.S. and the U.K.–and the lawyers who advise them.
This special program at the Cosentino City design showroom will discuss the rules that affect individuals moving across borders, focusing on opportunities to reduce tax after residence is established by transactions completed prior to the residence starting date.
Due to popular demand, Nina Krauthamer and Galia Antebi will reprise their discussion of the acquisition vehicles that can be used by foreign individuals for the purchase of U.S. real estate.
Trust instruments constitute a common estate planning tool in common law countries. While planning for future generations within the boundaries of a single jurisdiction constitutes the historical approach, families in today’s world do not necessarily live in the same country. This program serves as a primer on U.S. taxation of trusts having U.S. and non-U.S. settlors and beneficiaries.
This program will describe the unique challenges for mid-sized companies in planning, implementing, documenting, and managing controlled cross-border transactions and in dealing with tax authority controversy. Best practices and key points for advisors will be presented to explain how a company can meet its compliance obligations while acknowledging actual business practices.
This program will discuss the rules that affect individuals moving across borders, focusing on opportunities to reduce tax after residence is established by transactions completed prior to the residence starting date.
Q: How many ways are there to structure an investment in U.S. real property? A: Many. In this program, Nina Krauthamer and Galia Antebi will summarize the acquisition vehicles that can be used by foreign individuals for the purchase of U.S. real estate.
This Strafford live webinar will provide tax advisers and compliance professionals with a thorough and practical guide for reporting foreign trusts with U.S. owners or other U.S. nexus on Form 1040NR.
This Ruchelman international tax luncheon addresses planning opportunities for Spanish investment, including well-known and little-known vehicles for structuring investments in and through Spain, such as the E.T.V.E., the S.O.C.I.M.I., and the Z.E.C. The program features guest speakers José María Cusí and Juan Roda of CHR Legal, Barcelona.
Ruchelman P.L.L.C. provides a wide range of tax planning and legal services for foreign companies operating in the U.S., foreign financial institutions operating ...