Why Not Large Passthroughs as Corporations?

The essence of reform is getting rid of loopholes -- hopefully to pay for lower tax rates. There is no better corporate tax loophole than complete exemption from corporate tax. If some big businesses can remain completely exempt from corporate tax for no good policy reason, the signal is sent. If the...

IRS Gone Rogue? Investigating Policy on RICs’ Commodity-Related Investments

Higher prices at the pump got you down? Recent news stories suggest that commodity speculation may be a significant factor. (See, e.g., "Pump Prices Climb to Record High Level," Los Angeles Times (February 7, 2012)). The Commodity Futures Trading Commission (CFTC) oversees the financial market...

Practical Tax Considerations Relevant to U.S. Totalization Agreements

Totalization agreements are one of the best kept secrets in the international tax arena. Very few practitioners know they exist, and fewer still know what those agreements do... ... Totalization Agreements: What They Are A totalization agreement is a bilateral treaty between two countries that...