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Presentations

Biases, Heuristics, Blind Spots, and Pitfalls in I.R.S. Transfer Pricing Examinations

A Foreign Lawyer's Guide to U.S. International Tax Law: U.S. Tax Reform

A Foreign Lawyer's Guide to U.S. International Tax Law: Core Concepts

Global Law Week: BEPS Tax Panel

Video | Tax Planning for Brexit & Beyond

This program focuses on the critical issues of Eurocentric tax planning in the age of Brexit, B.E.P.S., and emboldened tax authorities. Seasoned tax professionals, including in-house counsel and global tax advisors, reflect on how these new realities impact tax planning between the U.K. and U.S.

Tax Planning for Brexit & Beyond

U.S. – U.K. Tax Planning: Coping with Uncertainty

Transfer Pricing for Mid-Sized Corporations

U.S. Citizens as Shareholders of Canadian Companies – Impact on Reorganizations and Other Canadian Tax Consequences

U.S. Citizens as Shareholders of Canadian Companies – Impact on Reorganizations and Other Canadian Tax Consequences

First presented at the Canadian Tax Foundation’s 68th Annual Tax Conference (2016) in Calgary, AB.

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U.S. Tax Update

Overview of U.S. Taxation of Cross Border Investments & Operations

Tax Planning for U.S. persons in Europe – Residency in Europe, Disclosure, Expatriation

Stanley C. Ruchelman and Beate Erwin attended the 2015 ITSG European Conference in Madrid, Spain.

Mr. Ruchelman and Ms. Erwin participated on the panel “Problems of U.S. Person Living in Europe,” which addressed banks that close accounts of U.S. persons, coming into compliance with tax return and F.B.A.R. reports, and planning for expatriation.

In conjuction with the conference, Mr. Ruchelman also spoke on the “Common Reporting Standard in the E.U.”

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Follow Up Work on B.E.P.S. Action 6: Preventing Treaty Abuse

How Much Equity is Enough in a U.S. Entity? When is Debt Treated as Debt?

Double Irish Sandwich: Google Feasts, European Governments Suffer Heartburn

The Life of an Outbound Investment from the U.S. into Canada

U.S. Tax Update: Inversions

A Foreign Grantor Trust is a Great Solution to Benefit U.S. Persons: A Look at How This is Done

F.B.A.R. - Litigation Aspects