Following their recent announcement regarding new partnership and global high wealth enforcement initiatives,1 the Internal Revenue Service (IRS) on Oct. 20 announced another enforcement initiative focusing on foreign corporations
Continue Reading IRS Ramps Up Enforcement Efforts; Focuses on Foreign-Owned and ‘Mega’ CorporationsThe Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of
Continue Reading Proposed Regulations for Qualified Foreign Pension Funds that are Exempt from U.S. Tax on Disposition of U.S. Real Property Interests
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
Continue Reading Welcome News for Non-U.S. Persons Investing into U.S. Businesses: U.S. Tax Court Rejects Long-Standing IRS Ruling
Dual American-Israeli citizens finally need to pay up.
After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or
Continue Reading October 20, 2016: Israeli-Americans Who Did Not Do Their Tax Homework at Greater Risk of Penalties (Jerusalem Post)
Come the end of September 2016, the Israeli Tax Authority will start forwarding data collected on U.S. citizens and green card holders with financial accounts in Israel to the U.S.
Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation. A 338(h)(10) election allows a buyer of
Continue Reading GT’s Quick Guide to Section 338(h)(10) Elections