Tello also brings experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.
parent with a foreign parent, thereby potentially avoiding U.
If the person is a noncitizen and nonresident, he or she is subject to U.
To some the explanation may sound reasonable and some may point to complicated U.
Respondents are particularly concerned about the use of revenue offsets impacting the U.
Frank Hirth is a taxation and accounting company with a focus on UK and U.
The effect of these difficulties in enforcing the taxation of nonresident taxpayers on domestic compliance is unclear, as is the effect of exemption of expatriates from U.
federal taxation; the relationship between tax rates and tax revenues; the comparison of U.
She has particular experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters, and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.
the sponsor of the bill, included the following provisions: a prohibition against the splitting of foreign tax credits from the income to which they relate; a denial of foreign tax credits with respect to foreign income not subject to U.
Complex rules that define and govern foreign personal holding companies, controlled foreign corporations, passive foreign investment companies and foreign sales corporations have been adopted to prevent the avoidance or significant deferral of U.
This Article advocates eliminating citizenship as a basis for imposing U.