Tax Law

Recent Posts

Practical Tax Considerations for Sovereign Wealth Fund Investments in the U.S.
Posted on 2 Jan 2012 by Rufus v. Rhoades & Alexey Manasuev

Introduction ... [ Prop. Treas. Reg. §§ 1.892-4 and 1.892-5 ]... partly supplement and partly replace the current temporary regulations under IRC Section 892 that have been in place since 2002 (and earlier). Importantly, the proposed regulations... Read More

Procter & Gamble v. U.S. and the FTC Noncompulsory Payment Requirement
Posted on 10 Feb 2011 by Rufus v. Rhoades & Alexey Manasuev

One of tax life's significant attractions for U.S. multinationals is the capacity to claim a foreign tax credit (FTC) for taxes paid in foreign jurisdictions. Much like many attractions, however, the opportunity to avoid double taxation by having... Read More

Preserving the Deceased Spousal Unused Exclusion Amount for the Surviving Spouse: IRC Section 2010(c) and Notice 2011-82
Posted on 20 Dec 2011 by Diane L. Mutolo

By Diane L. Mutolo INTRODUCTION: The Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010 amended IRC Section 2010(c) to allow, after December 31, 2010, a surviving spouse to increase his or her applicable exclusion amount... Read More

The Elusive Basis Problem of the Foreign Tax Credit Limitation
Posted on 2 May 2011 by Rufus v. Rhoades & Alexey Manasuev

As we know, Congress tinkered with the foreign tax credit (FTC) rules in 2010 in a number of ways. One of those changes was to add Section 901(m) (" Denial of foreign tax credit with respect to foreign income not subject to United States taxation... Read More