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Results: 1-10 of 304

Service prevails before Tax Court in self-employment tax case

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • January 21 2013

In a recent memorandum decision of the Tax Court in Howell, TCM 2012-303, a couple was held liable for a deficiency in self-employment taxes, plus

Tax credit report: Historic Boardwalk Hall, LLC v. Commissioner of Internal Revenue

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • October 26 2012

In a case of potentially far reaching implications, the Third Circuit Court of Appeals in Historic Boardwalk Hall, LLC v. Commissioner of Internal Revenue 1 reversed the U.S. tax court’s decision and issued a decision considered to be a seminal ruling on use of the Federal Historic Rehabilitation tax credit (Historic Tax Credit

Foreigners rush to invest in U.S. real property, but what are the tax issues?

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • December 19 2011

Foreign investment in U.S. real property has increased in recent years, driven in part by the weakness of the U.S. dollar in relation, most notably, to the euro, British pound and Canadian dollar

Service issues memorandum on application of dual consolidated loss rule applied to a foreign entity that is disregarded for U.S. income tax purposes

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • November 29 2011

In AM-2011-002, the IRS evaluated the separate return limitation on loss provision or “SRLY” with respect to the dual consolidated loss of a foreign disregarded entity under the check the box regulations

UK telecommunications company Vodafone recently receives favorable ruling from Supreme Court of India

  • Fox Rothschild LLP
  • -
  • India
  • -
  • June 26 2012

This past January, the Supreme Court in India ruled in Vodafone International Holdings B.V v. Union of India,Civil Appeal No. 733 of 2012 (arising from S.L.P. (C) No. 26529 of 2010) that the sale of stock of a company that was non-resident in India to another non-resident company was not subject to income tax in India

New tax relief act of 2010 extends 15 withholding on United States real property gains pass through to foreign persons by U.S. partnerships, trusts or estates

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • December 19 2010

A US partnership, trustee of a US trust, or executor of a US estate must deduct and withhold income tax on distributions attributable to the disposition of a US real property interest ("USRPI") to the extent it is includible in the income of a foreign partner, foreign beneficiary, or, in the case of a trust, a foreign person under the grantor trust rules per 671 et seq

Chief Counsel's advisory 201212008 holds green card holders working for foreign government in the United States were not exempt from U.S. tax

  • Fox Rothschild LLP
  • -
  • Italy, USA
  • -
  • July 1 2012

In CCA 20122008, the Chief Counsel’s Office ruled that compensation earned by green card workers while working for the Italian government in the United States is not exempt from the federal income tax pursuant to an 1878 U.S.-Italy consular convention on the basis that greencard holders can not be consular offices, nor under the 1984 U.S.-Italy income tax convention if Italy has the primary right to tax the worker, since the U.S. provides for foreign tax credits

Tax strategies for funds investing in China: China tax authorities aggressively enforcing gaar (general anti-avoidance rules)

  • Fox Rothschild LLP
  • -
  • China
  • -
  • April 22 2011

Chinese tax authorities have been aggressively enforcing the application of its GAAR and are likely to scrutinize exit tax residency and permanent establishment issues as they relate to nonresident funds and management companies

The permanent establishment of a foreign person in the united states under U.S. income tax convention

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • June 9 2010

It is a generally accepted axiom of international income taxation that a U.S. tax treaty will prevent the taxation of the business profits of a resident of a treaty county, unless the profits in question are attributable to a "permanent establishment" that is maintained by that resident in the United States

Canadian Tax Court rules Delaware LLC is U.S. resident for treaty purposes in TD Securities (USA) LLC v. Her Majesty the Queen

  • Fox Rothschild LLP
  • -
  • Canada, USA
  • -
  • April 20 2010

In a detailed and comprehensive review of the US-Canada Income Tax Convention, the recently issued Fifth Protocol, and the OECD Model Treaty and related Commentaries, as well as the domestic tax law treatment of single member limited liability companies, pass through entities and other organization, the Canadian Tax Court, in an opinion written by Patrick Boyle, on April 8, 2010, concluded that implicit in the clear intention of the OECD countries, including Canada and the US, that treaty benefits be enjoyed by TD LLC in the present circumstances, and given the context of the Canadian and US tax régimes and the text of the US Treaty, TD LLC must be considered to be a resident of the US for purposes of the US Treaty otherwise the treaty could not apply

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