US Tax Court Ruling Could Impact Frequent Flyers
A recent United States Tax Court decision increases the likelihood that frequent flyer miles could be subject to tax in the future (Docket No. 24414-12), despite a previous position taken by the...
View ArticleWhat is Coporate Tax Inversion ?
What is Tax Inversion ? To an extent, a tax inversion is in the eye of the beholder. But the basic idea of a tax inversion is this..Different countries tax corporate profits in different ways and at...
View ArticleEliminating US Death Tax Would Stimulate Growth
The Heritage Foundation (HF) has confirmed the increased jobs and growth that would arise by cancelling the United States estate tax, more commonly known as the “death tax.” Until 2012, estates paid a...
View ArticleFirms Expect Transfer Pricing Policy Impact From BEPS Project
A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation...
View ArticleIsraeli Beneficiaries Subject to New Tax
For the first time, U.S. (and other) foreign trusts with Israeli beneficiaries will be liable for a substantial income tax. Trust settlors face an array of decisions, some with deadlines as early as...
View ArticleIRS Issues Updated US Expatriate Tax Guide
The Internal Revenue Service (IRS) has released the 2014 update to Publication 54, the guide for use in preparing 2014 tax returns that outlines the special rules for United States citizens and...
View ArticleTax Foundation Suggests US Corporate Tax Reforms
In a new paper, the Tax Foundation has recommended that the United States should reduce corporate tax rates and amalgamate corporate and shareholder taxes. The TF points out that the US loses about...
View ArticleObama Wants a New Tax on U.S. Companies’ Overseas Profits
President Barack Obama will propose that U.S.-based companies pay a minimum 19 percent tax on their future foreign earnings, capturing profits that are now often beyond the government’s reach. Obama...
View ArticleUS House Aims For Foreign Real Estate Investment Boost
Bipartisan legislation has been introduced into the House of Representatives to amend the Foreign Investment in Real Property Tax Act (FIRPTA) of 1980 that requires foreign investors to pay taxes on...
View ArticleUS Model Tax Convention Changes To Tackle Inversions
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that...
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