International Tax Law Posts

Litigation Considerations When Facing the Economic Substance Doctrine

An Overview of the Taxation of Cross-Border Hedging and Notional Principal Contracts Involving CFCs

A Case for Bringing an APA Challenge to an IRS International Penalty Assessment

U.S.-U.K. Tax Treaty and U.K. Foreign Pension Planning Opportunities

An Overview of the Closer Connection Test and Treaty Tie-Breaker Provisions Available to Avoid U.S. Taxation on Foreign Source Income

Can Establishing Puerto Rican Residency Avoid Subpart F and GILTI Inclusions?

Are Foreign Insurance Companies Subject to the PFIC Tax Regime?

An Overview of the United States- Mexico Income Tax Treaty

Demystifying IRS Form 5471 Schedule G

Demystifying the New IRS Form 5471 Schedule M Used to Report CFC Transactions with Related Parties