Rhoades & Langer, U.S. International Taxation and Tax Treaties

Rhoades & Langer, U.S. International Taxation and Tax Treaties

Recent developments affecting FIRPTA, CFC "U.S. property," withholding obligations of employers located in U.S. possessions, foreign trusts and FBARs, foreign invesment trusts, and foreign estate and gift taxation. More on the following available in July at the LexisNexis® Store:

  • Controlled Foreign Corporations: Treasury has extended the rule on the definition of  "U.S. property" through 2010 for calendar year corporations.
  • U.S. Possessions: Withholding obligations explained for employers in U.S. possessions.
  • Foreign Investment in Real Property Tax Act (FIRPTA): Relevance of IRC Sec. 304 to foreign parents that own a U.S. real property holding corporation and that undertake an internal reorganization.
  • Foreign Trusts and FBARs: When does a trustee of a trust that owns a foreign bank account need to report?
  • Foreign Investment Trusts: Distinguishing between an investment trust and a business trust.
  • Foreign Estate and Gift Taxation: Personal liability of fiduciaries for amounts owed to the government, including unpaid taxes and penalties.