Cross-Border Tax Planning

In March 2021, the Council of the European Union adopted Directive 2021/514 amending – for the sixth time – Council Directive 2011/16/EU on administrative cooperation in the field of taxation
Continue Reading EU’s DAC7: New Tax Reporting Obligations for Platform Operators

On Jan. 7, 2021, the Department of Treasury and IRS issued final regulations (the Regulations) that provide guidance to the “carried interest” rules under Section 1061 of the Internal Revenue
Continue Reading 3-Year Holding Period Rule for ‘Carried Interests’ Addressed in IRS Final Regulations

On Aug. 9, 2019, the IRS issued proposed regulations (Proposed Regulations) addressing the U.S. federal income tax treatment of cross-border cloud transactions. The Proposed Regulations will not become effective until
Continue Reading IRS Clarifies U.S. Tax Treatment of Cross-Border Cloud and Other Online Transactions in Proposed Regulations

On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.
Continue Reading IRS Releases New Voluntary Disclosure Procedures for Post 9-28-2018 Offshore and Domestic Disclosures