Tax Law

Recent Posts

Cross-Border Benefits of Malta's Tax System and the U.S.-Malta Tax Treaty
Posted on 1 Sep 2011 by Withers Bergman LLP Tax Practice

By Mitchell R. Kops , Sanford J. Davis , William J. Kambas , and Theodore C. Ahlgren The authors would like to thank Angela M. Klemack , an associate at the firm, for her valuable assistance in the preparation of this article. ... Malta has... Read More

Practical Tax Considerations Relevant to U.S. Totalization Agreements
Posted on 6 Jul 2012 by Rufus v. Rhoades & Alexey Manasuev

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... Read More

Repatriation Tax Holidays and IRC Section 965
Posted on 11 Jul 2012 by LexisNexis Tax Law Community Staff

By Mary Riley * The debate over corporate tax reform has largely centered on lowering the corporate tax rate and, more radically, transitioning from a worldwide to a territorial system of international taxation. [Donald J. Marples and Jane G. Gravelle... Read More

Tax Considerations for Taxpayers Applying the Economic Substance Doctrine
Posted on 5 Apr 2012 by Rufus v. Rhoades & Alexey Manasuev

The Background In 2010, Congress codified the economic substance doctrine, but left numerous unanswered questions for taxpayers on how to apply the doctrine. Along with codifying the economic substance doctrine, Congress also enacted strict liability... Read More

Inversion Regulations: The Illusory "Safe Harbor"
Posted on 3 Oct 2012 by Rufus v. Rhoades & Alexey Manasuev

[On June 7, 2012], Treasury issued temporary and proposed ( T.D. 9592 ) and final ( T.D. 9591 ) regulations under IRC Section 7874 to "provide more certainty in applying IRC § 7874 " and to "improve the administrability" of the... Read More