International Taxation Articles To Search this Article Database Enter: Key Word(s), or Code section [e.g. 162(a)], or Regulation section [e.g. 1.162-1] Corporate Taxation International Taxation Real Estate Taxation Tax Controversy and Litigation State and Local Taxation Employee Benefits Executive Compensation Estate and Personal Tax Planning All Articles     Foreign Account Tax Compliance Provisions Have Far-Reaching Effect Canadian Tax Foundation - 61st Annual Conference, April 01, 2010   Reflections on the Application of Income Tax Treaties to Hybrid Entities That Earn Non-FDAP Income International Tax Journal, January 01, 2010   IRS Extends Deadline For Voluntary Disclosure Program R&H Letter to Clients and Friends, September 24, 2009   Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program R&H Letter to Clients and Friends, July 22, 2009   Should Retirees Still Consider Expatriating? Journal of Retirement Planning, May 01, 2009   Proposed Legislation Affecting Assets Held Overseas Rothschild Trust Review, April 01, 2009   U.S. Adopts Exit Tax Upon Expatriation BNA Tax Planning International Review, December 16, 2008   Forfeiture of Deductions for Failure to File Timely Return: (Swallows Holding, Ltd. v. Commissioner) New York Law Journal, April 17, 2008   Proposed Earnings-Stripping Rules May Affect Canadian Investments in the United States The Canadian Tax Journal, September 01, 2007   Accessing U.S. Income Tax Treaties: Current Trends in the Limitation on Benefits Article International Tax Journal, June 01, 2007   Notice 2007-13 Announces New and Improved Substantial Assistance Rules Tax Management International Journal, April 13, 2007   Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test International Tax Journal, February 01, 2007   Cleansing the PFIC Taint Just Got Easier: New Regulations Permit Purging Elections for Closed Years Tax Management Memorandum, April 03, 2006   CA-2's Narrow View of Pasquantino Does Not Affect Enlarged Scope of Federal Fraud and Money Laundering Journal of Taxation, January 15, 2006   Are Your Non-U.S. Executives Prepared for U.S. Estate Tax? The Metropolitan Corporate Counsel, December 01, 2005   Recent Developments Make It Easier For U.S.-Based Multinationals To Dispose Of Foreign Subsidiaries Canadian Tax Journal, March 01, 2005   A One-Time Tax Break For US Multinationals The Metropolitan Corporate Counsel, January 01, 2005   Pending Protocol Will Prevent Inverted Corporations from Accessing the Barbados Treaty Tax Management International Journal, November 12, 2004   American Jobs Creation Act of 2004 International Tax Provisions R & H Letter to Clients and Friends, November 11, 2004   Treaty Conflicts in Categorizing Income as Business Profits Caused by Differences in Approach between Common Law and Civil Law Bulletin for International Fiscal Documentation, November 01, 2004   Avoiding U.S. Tax On Foreign Sales To U.S. Customers The Metropolitan Corporate Counsel, October 01, 2004   IRS Issues A Warning To Canadian Law Firms With U.S. Branch Offices The Canadian Tax Journal, March 01, 2004   Proposed Amendment to FIRPTA Could Make U.S. REITs More Attractive to Canadian Real Estate Investors The Canadian Tax Journal, March 01, 2004   U.S. Reduced Rates Now Apply to Dividends of Non-Corporate Taxpayers The Canadian Tax Journal, September 01, 2003   September 15th Due Date for Waiver of Filing Deadline for Foreign Taxpayers R&H Letter to Clients and Friends, August 14, 2003   Gain Recognition Agreement Regulations Could Stand Some Clarification Taxation of Global Transactions, June 01, 2003   Proposed Transportation Regulations - Suggestions for Final Course Correction Tax Management International Journal, May 09, 2003   Interest Stripping Changes Affecting U.S. Corporations Seem Likely; Only the Details Remain Opaque The Canadian Tax Journal, February 01, 2003   Thomas Bill Currently Pending in Congress Includes Many Important Foreign Tax and Other Legislative Proposals The Canadian Tax Journal, December 01, 2002   FSA 200220005: IRS Again Attempts to Void Contract Manufacturing Arrangements Under Subpart F Taxation of Global Transactions, December 01, 2002   Final Regulations on Payments by 'Reverse Hybrid' U.S. Entities Include Narrow Limits on Treaty Use The Canadian Tax Journal, September 01, 2002   Estate Tax Conflicts Resulting from a Change in Residence International Fiscal Association -- 56th Congress, August 25, 2002   Gains Tax vs. Inheritance Tax International Fiscal Association -- 56th Congress, August 25, 2002   Electronic Arts: Taxpayers Appear to Win a Battle on the Subpart F Contract Manufacturing Front Taxation of Global Transactions, August 15, 2002   IRS Wields the Two-Edged Sword of Code Sec. 956 Taxation of Global Transactions, April 15, 2002   U.S. Export Taxation, Treaty Challenges, and Filing Leniency Bear Watching Canadian Tax Journal, March 15, 2002   'Textron' Makes for Mischief: Tax Court Opens a Pandora's Box Taxation of Global Transactions, January 15, 2002   What to Expect in the New US-Canada Treaty Canadian Tax Journal, December 15, 2001   Accessing the Manufacturing Exception to Subpart F Through Contract Manufacturing Arrangements Journal of Taxation of Global Transactions, December 01, 2001   U.S. Taxation of E-Commerce under Subpart F -- Missing Pieces Leave Uncertainty 2001 International Bureau of Fiscal Documentation, October 15, 2001   Appeals Court Invalidates US-Netherlands 'Double-Dip' Financing Structure Canadian Tax Journal, October 01, 2001   IRS Proposes Regulations on Treaty Benefits for Payments by 'Reverse Hybrid' US Entities Canadian Tax Journal, June 01, 2001   Considerations for Underlying Foreign Corporations ALI-ABA Estate Planning Course Materials Journal, April 30, 2001   Appeals Court Adheres To Precedent, Tells IRS That It's Too Late To Issue Regulations Canadian Tax Journal, February 01, 2001   Transfers to Foreign Trusts: Treasury Proposes Regulations Under §§679 and 684 Tax Management International Journal, January 12, 2001   Taxation Caused by or After a Change in Residence Tax Notes International, August 07, 2000   New U.S. Withholding Rules for Hybrids and Passthroughs Canadian Tax Journal, June 01, 2000   When Does E-Commerce Result in a Permanent Establishment? The OECD's Initial Response Tax Management International Journal, April 14, 2000   Update of Recent Actions by U.S. Taxing Authorities Canadian Tax Journal, March 01, 2000   IRS Scrambling to Attack Lease Strips Tax Management International Journal, January 14, 2000   U.S. Court Finds Foreign Tax Credit Strip Does Not Compute Canadian Tax Journal, December 01, 1999   APA Disclosure: Can The Process Survive? Canadian Tax Journal, October 15, 1999   Lessons in Avoiding Transfer Pricing Penalties: DHL Corp. Canadian Tax Journal, June 01, 1999   Loss 'Importation' -- Opportunities and Limitations Tax Notes, February 15, 1999   Laidlaw Taxpayer Crashed and Burned, Losing Billion-Dollar Debt-Equity Case Canadian Tax Journal, December 01, 1998   When is a U.S. Subsidiary a Permanent Establishment? Canadian Tax Journal, October 01, 1998   Taiyo Hawaii Co., Ltd.: Destined for Frequent Citation Canadian Tax Journal, June 01, 1998   Electronic Commerce: Taxation of Services Provided via the Internet R & H Newsletter -- Tax Insights, October 01, 1997   Are You a U.S. Citizen? Canadian Tax Journal, October 01, 1997   Electronic Services: Suggesting a Man-Machine Distinction Journal of Taxation, August 15, 1997   Canadian Investment in the United States after the Taxpayer Relief Act of 1997 Canadian Tax Journal, March 01, 1997   Internet Sales Pose International Tax Challenges Journal of Taxation, June 01, 1996