Eshel v. Comm, 118 AFTR 2d 2016-XXXX (CA Dist Col), 08/05/2016 U..S Court of Appeals for the District of Columbia Circuit In many ways Eshel could be a Treaty Interpretation 101 class. The case focuses on the AGREEMENT ON SOCIAL SECURITY BETWEEN THE UNITED STATES OF AMERICA AND THE FRENCH REPUBLIC (treaty). We need to […]
Eshel v. Commissioner: A Refresher in Translating Tax Treaties Read More »
reprinted with permission from Global Tax Weekly, Wolters Kluwer by Marc Schwartz and Paul Tadros All Section references are to the US Internal Revenue Code, 1986, as amended and the US Department of the Treasury regulations (collectively, “Code”) promulgated thereunder unless stated otherwise; Unless stated otherwise, the terms “tax” and “taxation” mean income tax; Unless
A Foreign Trust Investing In The US: ‘Ordinary’ Or ‘Business’ Trust? Read More »
Last fall, the Coca-Cola Company learned that a five-year long IRS audit resulted in a “notice of deficiency,” meaning that according to the IRS the company owed an additional $3.3 billion in taxes for the years 2007, 2008 and 2009. Coca-Cola is challenging the IRS in U.S. Tax Court. The Atlanta Business Chronicle recently released
Paul Tadros and Marc Schwartz Interviewed on Coke’s IRS Fight Read More »
The U.S has income tax treaties with more than 60 countries, helping to advance global trade by reducing double taxation and providing more certainty in international business, among other items. In order to serve their purpose, income tax treaties must be updated to parallel growing developments in tax policy, the international economy, and new treaties
More Frustration Over Tax Treaty Delays Read More »
Anthony Ji’s first publication attempt was accepted by Wolters Kluwer in its Global Tax Weekly: a closer look. Anthony’s article focuses on direct versus indirect foreign tax credits, the impact on individuals and the advantages / disadvantages of making an election under Internal Revenue Code Section 962 to claim the benefits of an indirect credit.
Anthony Ji Publishes First Article as Part of the SI Team Read More »
Schwartz International was pleased to participate in Steve Kilpatrick’s radio show on Business Radio X to discuss global tax issues for businesses and individuals. Steve and Marc discussed international tax issues ranging from common problem spots and mistakes to complex planning and implementation and also included details on the IRS’ Offshore Voluntary Disclosure Program
Schwartz International Radio Broadcast on Global Tax Read More »
In addition to the out of the ordinary things Marc is involved in, during the month of November he grew out a pretty ugly mustache and raised money to help raise awareness for Men’s Health with the Movember Foundation. The Movember Foundation is a global charity committed to men living happier, healthier, longer lives. Since
See latest updates from India, France and The Netherlands: Corporate Alliance October Newsletter
See the Latest Corporate Tax Alliance Update Read More »
In addition to assisting the Schwartz International team with the everyday business flow of the firm, administrative assistant Qulanda Moore, who is also a writer/director/producer, celebrates a milestone of 20k+ views on her web series “The Single Life” which airs on the YouTube channel, MOQtv. “The Single Life” is a comedic-drama that centers on the
From International Tax to International Entertainment Read More »
Paul Tadros and Marc Schwartz participated in the Corporate Tax Alliance’s (CTA) annual meeting last week in Madrid, Spain (October 2-3). Tax professionals representing 20+ jurisdictions, ranging from the western hemisphere, Europe and Asia met to discuss current trends in global tax, including BEPS (base erosion and profit shifting), tax treaties and other items related to our
Tadros and Schwartz Discuss International Tax in Madrid Read More »
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