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Does the U.S.- German double tax treaty also apply to a U.S. limited liability company?

Bryan Cave LLP
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Germany, USA
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April 29 2013

Whenever a U.S. Limited Liability Company ("US-LLC") is involved in cross-border shareholding structures concerning the United States

Reporting target’s deductions in an acquisition

Bryan Cave LLP
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USA
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April 29 2013

Corporate clients often want a transaction to close at the beginning or end of the day. Generally, the reason for choosing the beginning or end of

Consolidated Edison and historic tax credit and new markets tax credit transactions

Bryan Cave LLP
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USA
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April 29 2013

In January 2013, the Federal Circuit Court of Appeals handed down a decision in Consolidated Edison Co., Inc. of New York v. United States ("ConEd"

New proposed regulations change the requirements of Circular 230

Bryan Cave LLP
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USA
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January 25 2013

On September 17, 2012, the Treasury issued new proposed regulations that govern practice before the IRS. These regulations modify the standards

On-site communications antenna power generation constitutes qualifying REIT income

Bryan Cave LLP
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USA
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April 29 2013

Communications antenna and cellular tower leasing companies have recently been converting to real estate investment trusts ("REITs") in the wake of a

Avoiding an accuracy-related penalty for reasonable cause based on reliance on a tax professional

Bryan Cave LLP
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USA
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April 29 2013

Taxpayers seeking abatement from the accuracy-related penalty imposed under section 6662(a) of the Code often argue reasonable cause based upon

Improperly cancelled life insurance policy leads to taxable income

Bryan Cave LLP
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USA
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April 5 2012

In Estate of Feder, Yulia Feder learned the hard way that failure to properly cancel a life insurance policy can lead to income tax consequences

Update on FICA taxation of severance payments

Bryan Cave LLP
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USA
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April 29 2013

The Supreme Court recently granted the government an extension of time to file a petition for the Supreme Court to review the Sixth Circuit's

Summary of new provisions in IRS Draft Instructions for Form 706 for decedents dying in 2012

Bryan Cave LLP
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USA
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September 24 2012

As we told you last week, the IRS recently released Draft Instructions for Form 706 for decedents dying in 2012, which can be found here

You can’t hide from the IRS

Bryan Cave LLP
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USA
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May 2 2013

The general rule is that an IRA is exempt from the claims of creditors. Indeed, the Federal Bankruptcy Code provides in Sections 522(b)(3)(C) and

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Search results

Does the U.S.- German double tax treaty also apply to a U.S. limited liability company?

Reporting target’s deductions in an acquisition

Consolidated Edison and historic tax credit and new markets tax credit transactions

New proposed regulations change the requirements of Circular 230

On-site communications antenna power generation constitutes qualifying REIT income

Avoiding an accuracy-related penalty for reasonable cause based on reliance on a tax professional

Improperly cancelled life insurance policy leads to taxable income

Update on FICA taxation of severance payments

Summary of new provisions in IRS Draft Instructions for Form 706 for decedents dying in 2012

You can’t hide from the IRS

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