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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.

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.

IRS issues proposed regulations addressing taxation of US citizens or residents receiving gifts or bequests from expatriates

USA - October 8 2015 The Heroes Earnings Assistance and Relief Tax Act of 2008 (the “HEART Act”) is well-known for imposing an exit tax on US citizens and long-term green…

Elliott H. Murray, Glenn G. Fox, Gregory C. Walsh, Lyubomir Georgiev, Paul F. DePasquale.

North America tax news & developments - volume 15, issue 2

USA - April 27 2015 On March 27, 2015, the IRS issued its Annual Report Concerning Advance Pricing Agreements (Announcement 2015-11, I.R.B. 2015-15) (“2014 APA Report”)…

Barbara J. Mantegani, Erin Tyler Brewster, Kai R. Kramer, Richard L. Slowinski, Thomas R. May.

Old but not forgotten: adjustments to annual layers of pre-1987 foreign income taxes

USA - January 5 2015 On October 31, 2014, the IRS released CCA 201444039, which provides that a US taxpayer has "no support in the Code, the regulations, or sound tax…