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Substantial Presence? PE? Treasury and the IRS prescribe treatment for tax maladies

USA - April 29 2020 The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction…

Robert S. Chase II, Mary E. Monahan, Carol P. Tello, Brian Tschosik

US companies testify supporting USTR investigation of France’s digital services tax, on which US and France may have reached a deal

United Kingdom - August 29 2019 On July 10, 2019, the US Trade Representative (USTR) initiated an investigation under Section 301 of the Trade Act of 1974 (Trade Act) with respect…

Robert Christoffel, Amanda P. Cooper, Carol P. Tello, Stefanie Wood

The season of giving - proposed regulations ease FATCA reporting burdens

USA - December 20 2018 On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the…

Michael R. Miles, Amanda P. Cooper, Saren Goldner, Robert S. Chase II, Mary E. Monahan, Daniel R.B. Nicholas, Carol P. Tello

Legal Alert: GILTI by consolidation

USA - September 25 2018 Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under…

Aaron M. Payne, Randy Buchanan, Robert Christoffel, Robert S. Chase II, Krystal S. McKay, Daniel R.B. Nicholas, Margaret R. Pope, Jed Rogers, Carol P. Tello, Brian Tschosik

In transition—proposed section 965 regulations incorporate and expand on prior guidance

USA - August 20 2018 On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published…

Aaron M. Payne, Robert Christoffel, Robert S. Chase II, Taylor M. Kiessig, Daniel R.B. Nicholas, Jed Rogers, Michael S. Spencer, Lauren E. Stewart, Rich Sun, Carol P. Tello, Brian Tschosik, Stefanie Wood