The United States, Australia and the United Kingdom gang up on international tax evasion *

Australia, United Kingdom, USA - May 15 2013
In a news release on May 9, 2013, the tax authorities of the United States, Australia and the United Kingdom announced a plan to share tax…

Co-authors: Edward Tanenbaum.

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IRS issues regulations on outbound asset transfers *

USA - April 15 2013
The IRS recently issued final, temporary and proposed regulations concerning transfers of assets by U.S. corporations to foreign corporations in…

Co-authors: Edward Tanenbaum.

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Gain on sale of partnership interest by nonresident alien taxable as effectively connected income *

USA - March 15 2013
In recently released Field Attorney Advice, the IRS reaffirmed its position that gain on the sale of a partnership interest by a nonresident alien…

Co-authors: Edward Tanenbaum.

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Final FATCA regulations are finally here *

USA - February 15 2013
On January 17, 2013, the U.S. Treasury and the IRS issued long-awaited final regulations under the Foreign Account Tax Compliance Act (FATCA)…

Co-authors: Jim Croker, Clay Littlefield, Edward Tanenbaum.

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IRS may apply economic substance doctrine to securities lending transactions entered to avoid U.S. withholding tax *

USA - January 15 2013
In generic legal advice released in November 2012 (AM 2012-009), the Chief Counsel's Office, applying the economic substance doctrine, disregarded a…

Co-authors: Jack Cummings.

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