A Spanish translation of this post appears below. La traducción al español de este artículo aparece a continuación. The Tax Cuts and Jobs Act provided clarity to a question of how to treat gain or loss from the sale or exchange of a partnership interest held by a foreign person….
Shareholders in foreign businesses could find themselves hit with an immediate tax on offshore earnings under the recently passed “Tax Act,” officially known as “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018.” Before the Tax…
Japan has long been one of the United States’ largest trading partners. Japan is also one of the United States’ longest-standing tax treaty partners. The first U.S.-Japan income tax treaty was concluded in 1954. Updated treaties were signed in 1971 and 2003, and a protocol in 2013 further modernized the…
The Sarasota-Manatee area recently hosted the 2017 World Rowing Championships, bringing nearly a thousand athletes from seventy countries to the world-class rowing facilities at Nathan Benderson Park. The tax consequences of such a visit were probably far from the thoughts of the rowers, coaches, support teams, and fans arriving from…
The Canada Revenue Agency (“CRA”) announced at the May 26 meeting of the International Fiscal Association in Montreal that limited liability limited partnerships and limited liability partnerships organized under the laws of Florida or Delaware will be taxable as corporations for Canadian income tax purposes. The CRA has treated US…