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Income Taxes › Tax Planning › Tax Treaty

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Strafford

[Webinar] Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Income and Expenses, FTCs - March...

Strafford on

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more

Kramer Levin Naftalis & Frankel LLP

US-Chile Bilateral Income Tax Treaty Enters Into Force

Kramer Levin Naftalis & Frankel LLP on

On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive bilateral tax treaty signed by the United States to enter...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

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On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

A&O Shearman

U.S.-Chile Income Tax Treaty Enters Into Force

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On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more

Freeman Law

Reviewing a Foreign Legal Structure

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Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Freeman Law

Tax Treaties and Exempt Income

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Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more

Freeman Law

Navigating the Branch Profits Tax

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The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more

Freeman Law

Withholding Agents and FDAP Income

Freeman Law on

Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more

Freeman Law

FDAP Income

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The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more

Morgan Lewis

Potential Changes to Taxation of Dividends in Kazakhstan

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During an address to the Parliament’s Mazhilis on 11 January 2022, the president of Kazakhstan instructed the respective state bodies to “secure a strict monitoring, inspection, and control of all transactions and persons who...more

Freeman Law

IRS Targets Participants in Malta Pension Plan Transactions

Freeman Law on

This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more

Freeman Law

The IRS’s Dirty Dozen Tax Schemes—Installment Four

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The IRS recently concluded its 2021 four-part series of the “Dirty Dozen” tax-related scams. The fourth installment focuses on what the Service refers to as “schemes peddled by tax promoters, including syndicated...more

Freeman Law

The Tax Court in Brief - January 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

Freeman Law

International Tax Treaty: The United Kingdom

Freeman Law on

Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

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Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Morgan Lewis

Rules on Controlled Foreign Corporations in Kazakhstan May Change

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The Kazakhstan Tax Code may change so that controlled foreign corporation rules will not apply to foreign persons that are residents of countries having a double tax treaty with Kazakhstan. Kazakhstan residents (both...more

Foodman CPAs & Advisors

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

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IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

McDermott Will & Emery

[Event] The US-Chile Tax Treaty And Its Imminent Impact On Taxpayers – December 2019 Approval Expected - September 25th, Miami, FL

McDermott Will & Emery on

After nearly a decade of being put on hold, several members of the Senate Foreign Relations Committee have recently indicated that the first US-Chile Income Tax Treaty is expected to be approved by the end of the year. The...more

Foodman CPAs & Advisors

How to determine an Individual’s Residency for Tax Treaty Purposes?

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The guidelines for determining an Individual’s tax residency are as follows: - An Individual Taxpayer is a resident based on the laws of one treaty-partner country and is considered to be a resident of that country for...more

Akin Gump Strauss Hauer & Feld LLP

New Circular Letter on Lump-Sum Taxation in Switzerland

Akin Gump Strauss Hauer & Feld LLP on

• The Swiss Federal Tax Administration published a new circular letter on lump-sum taxation. • The circular sets out a minimum taxable income of CHF 400,000 even if the living expenses are lower. • The stricter rules...more

Butler Snow LLP

5 Common Tax Misconceptions Facing U.S. Persons Living Outside the U.S.

Butler Snow LLP on

Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more

Bilzin Sumberg

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

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