Tags » International Tax

IRS Issues Final Regulations for Foreign Owned Single Member LLCs

The Internal Revenue Service (“IRS”) issued final regulations that will increase reporting requirements for certain foreign owned single member limited liability companies (“LLC”). When a single member LLC is formed, for federal tax purposes, it is a disregarded entity by default. 172 more words


Understanding Treaty Shopping

The world is increasingly becoming 1 large country. Borders are shrinking and commerce is growing. However, despite the increasing trend of cross-border business, a significant factor remains that each country and its economy is unique. 2,982 more words

Azadi Bachao Andolan

Apple, Ireland, and State Aid: The EC Decision

By: Sam Brunson

In August, the European Commission announced that Ireland had illegally granted state aid to Apple, and that it would be required to recoup over $13 billion in back taxes from Apple. 990 more words

International Tax

International Tax Climates: U.S. Rankings

How Competitive is the U.S. Taxing System Worldwide?

Contributing Author: William A. Raabe

We’ve been hearing for the past decade about the “Double Irish with a Dutch Sandwich… 1,033 more words

International Court of Justice rejects India's opposition to British arbitrator in Vodafone-India tax case

The International Court of Justice has upheld its appointment of Sir Franklin Berman as the chief arbitrator in the Vodafone-India tax case.

Vodafone and the Indian government are currently embroiled in a tax dispute after the Indian government retroactively slugged Vodafone with an RS 22,100 Crore ($3.2 billion) tax bill in relation to Vodafone’s acquisition of a 67% stake in Hutchison Essar Telecom services in 2007. 225 more words

International Court Of Justice

Who says MNCs want to keep the earnings offshore

IRS recently stated that the U.S. based holding companies claimed $18.3 billion in foreign tax credit in 2013 which is up from $8.17 billion in the previous year. 85 more words

Global Tax

ClassCrits IX: The New Corporatocracy and Election 2016

Surly bloggers Sam Brunson, David Herzig and I (and Leslie Book over at Procedurally Taxing) are attending the ClassCrits IX conference hosted by Loyola University Chicago School of Law today and tomorrow. 272 more words