For those interested in tax treaty implications of the latest US tax reform, we recently published an article with Tax Notes International that took a specific position on an issue being highly contested in the international tax community. While we… Read more…
Tag: foreign tax credit
IRS agrees that French CSG is a Creditable Tax
The Internal Revenue Service (IRS) has recognized in a June 14th court filing that the French Generalized Social Contribution (CSG) and the Contribution for the repayment of social debt (CRDS), are, in fact creditable taxes for US tax purposes. This… Read more…
Simone Alting speaks at the GSCPA Decision Makers Conference
On Thursday, April 25th Simone Alting spoke about International Tax Policy at the Georgia Society of CPAs (GSCPA) Decision Makers Conference. Here is a snippet of what she covered: Despite budget constraints and key vacancies, the IRS continues to target… Read more…
PREVIOUSLY TAXED EARNINGS AND PROFITS (“PTEP”) UNDER THE TCJA
“Oh, how I long for the good ‘old days’ (just 2016, not far back)” Introduction For those that remember, the subpart F rules were introduced in 1962 when statutory rates were extremely high and, until December 31, 2016, we all… Read more…
Marc Schwartz Participates in International Tax Talk
Marc Schwartz was pleased to participate in the March 21, 2018 panel on international tax reform sponsored by Taylor English. Marc spoke alongside Vivian Hoard, an experienced tax litigator with Taylor English, and Iliana B. Malinov, a partner with… Read more…