Category Archives: Tax

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Welcome News for Non-U.S. Persons Investing into U.S. Businesses: U.S. Tax Court Rejects Long-Standing IRS Ruling

On July 13, 2017, the U.S. Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner,1 rejected the long-standing Internal Revenue Service (IRS) position that a non-U.S. person is taxed on the sale of an interest in an entity that is a “partnership” for U.S. federal income tax purposes (hereinafter, a partnership) … Continue Reading

U.S. Treasury Announces $7 Billion Allocation of New Markets Tax Credit

The United States Department of the Treasury’s Community Development Financial Institutions Fund (CDFI) has last week announced $7 billion in New Markets Tax Credit (NMTC) awards with the goal of economically revitalizing low-income communities across the country.  Particular outcomes that the CDFI hopes to achieve with this round of awards include investment in nonmetropolitan areas, … Continue Reading

New Tax Implications for Israeli Citizens with Foreign Bank Accounts

On Aug. 1, 2016, the Israel Tax Authority announced that it has received information on over 8,000 Israeli clients with foreign bank accounts in Switzerland. The receipt of this list has major tax implications for Israeli citizens who are required to report foreign bank accounts to the Israel Tax Authority. Moreover, this will have additional … Continue Reading

Incentive Stock Options vs. Nonqualified Stock Options – A General Summary

Introduction When reviewing U.S. stock option plans for our foreign clients, we are constantly asked to explain the difference in tax consequences between incentive stock option (ISO) plans and nonqualified stock option (NSO) plans. This is a frequently asked question as many U.S. companies offer their employees options to buy company stock at a specified … Continue Reading

Treasury Proposes New Regulations on Disregarded Entities Owned by Nonresident Aliens

If you ask the typical American tax administrator to name a notorious tax haven they would probably name the Cayman Islands or the British Virgin Islands or some other small nation that makes a disproportionate amount of its budget by accommodating international tax structures. Ask the same question of a European tax administrator and the … Continue Reading

What’s the Deal with Par Value?

A common question that we are constantly asked by Israelis and other international clients interested in forming a corporation in the United States is what value we should use for the corporation’s par value. In addition, during the course of performing diligence on a target U.S. corporation, there are always references to the par value … Continue Reading

What Every Fund Manager Wants to Know about the ECI Rules (But is Afraid to Ask)

Things can go cataclysmically wrong for offshore fund managers investing in the United States in the most unexpected manner, at the most unexpected time. A complete list of potential fund-manager tsuris is beyond the scope of this Alert. However, one issue that routinely keeps fund managers awake at night is the specter of their funds’ … Continue Reading

Greenberg Traurig Issues Spring 2015 China Newsletter

With the establishment of the Prime Minister’s Office Israel-China Task Force in March, led by the National Economic Council and the Israel Export Institute, it is expected that the bilateral economic ties between China and Israel will greatly increase.  Greenberg Traurig, with offices in both Tel Aviv and Shanghai, is in a unique position to provide its … Continue Reading

U.S. Fiscal Cliff Averted, or Simply Postponed?

On January 2, 2013, President Obama signed the “American Taxpayer Relief Act of 2012” into law. The Act imposes an income tax increase to 39.6% (from 35%) on U.S. taxpayers earning more than $400,000 ($450,000 for married couples filing jointly) and raises the estate tax rate to a maximum of 40% (from 35%). The federal income tax rate on long-term capital gains has been increased from 15% to 20% for the top income-earners beginning in 2013.… Continue Reading
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