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PFIC: Determining Ownership and Reporting Requirements Under New Regulations

USA - January 13 2017 On December 27, 2016, the US Treasury Department and IRS published final regulations (TD 9806) that provide guidance on determining ownership of a…

Daniel W. Hudson.

IRS issues new notice on FATCA compliance

USA - January 7 2014 On 29 October 2013, the IRS issued Notice 2013-69 (the "Notice") providing a draft of the agreement ("FFI Agreement") that foreign financial…

Impact on Business Valuations of Lapsed Rights and Restrictions on Liquidation of an Interest: Is this the End of Valuation Discounting as we Know it? Section 2704 Proposed Regulations Released

USA - August 21 2016 On August 2, 2016, the Treasury Department released the much anticipated proposed Treasury Regulations under Code Section 2704, providing…

Ceci Hassan, Daniel W. Hudson, Elliott H. Murray, Glenn G. Fox, Kevin Keen.

Updated guidance on PFIC and Form 5471 reporting

USA - February 21 2014 In 2010 Congress enacted section 1298(f) with the seemingly simple requirement that each US person who is a shareholder of a passive foreign…

The Foreign Earned Income Exclusion requires more than just living overseas

USA - September 30 2016 Each year thousands of the US citizens and tax residents living overseas take advantage of the several tax breaks provided to them in…

Caleb Sainsbury.