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Articles / International Taxation

Published: Tax Notes, November 12, 2018
Download the file for The Discreet Charms of the Dividends Received Deduction.
Published: Tax Management Real Estate Journal, November 7, 2018
Download the file for Qualified Opportunity Zones and Select Partnership Issues.
Published: Tax Notes, October 29, 2018
Download the file for Simultaneous Equations for Simpler Tax Analysis.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 16, 2018
Download the file for Loan v. Distribution:
Published: Tax Notes, July 2, 2018
Download the file for To the Frying Pan: New Virtues of Subpart F over GILTI.
by Joshua A. Rabinovits
Published: Tax Notes, April 30, 2018
Download the file for The End of Eternity: Anomalies in Transition to Territoriality.
Published: Tax Management International Journal, April 13, 2018
Download the file for Direct Foreign Tax Credit and GILTI: The Curious Incidence of the Credit That Was Not Cut.
by Ellen Seiler Brody
Published: TaxStringer, February 1, 2018
Download the file for The Tax Cuts and Jobs Act - Traps for the Unwary Accountant.
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Download the file for Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32.
by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Download the file for Reliance on a CPA As Reasonable Cause:
by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
Download the file for Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income.
by Michael S. Grisolia
Published: Bloomberg BNA Tax Management Memorandum, November 14, 2016
Download the file for Eradicating Double Non-Taxation: A Comparative Analysis of the 2016 U.S. Model Income Tax Convention and OECD/G20 BEPS Action 6.
by Charles S. Nelson
Published: Tax Notes, July 25, 2016
Download the file for Managing Global Tax Controversy: A Primer for the U.S. Multinational.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 16, 2016
Download the file for Recent Guidance Regarding Deduction of Fines.
by Michael J. Miller
Published: Canadian Tax Journal, August 1, 2014
Download the file for Snowbirds Flying Blind: Beware the US Residence Trap.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 19, 2014
Download the file for Stock Rights Under §457A: Revenue Ruling 2014-18.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 20, 2014
Download the file for Property Abandonment Results in Capital Loss:
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2013
Download the file for
by Michael J. Miller
Published: The Canadian Tax Journal, October, 2013
Download the file for Options to Consider for Non-US Investors in US Real Estate.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 15, 2013
Download the file for Can the Issuance of Form 1099-C Cancel a Debt?.
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, March 5, 2013
Download the file for Expats Live in Fear of Malevolent Time Machine.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 20, 2012
Download the file for More About Step Transactions: G.D. Parker v. Commissioner.
Published: R&H Letter to Clients and Friends, January 4, 2013
Download the file for American Taxpayer Relief Act of 2012: International Tax Provisions.
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
Download the file for IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad.
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, May-April, 2012
Download the file for Foreign Asset Reporting Under Code Section 6038D.
by Mark David Rozen, Ellen Seiler Brody
Published: BNA Tax Planning International Review, March 01, 2012
Download the file for New Proposed Regulations Provide Some Welcome Relief for Foreign Financial Institutions under FATCA.
by Michael J. Miller
Published: International Tax Journal, July 01, 2011
Download the file for Shameful Double Taxation of Individual Expatriates.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
Download the file for IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions.
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
Download the file for IRS Further Extends Deadline for 2009 and Prior FBARs Required to be Filed by U.S. Persons With Signature Authority but No Financial Interest in Foreign Accounts.
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, May 13, 2011
Download the file for The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around? .
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
Download the file for Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
Download the file for Certain Taxpayers May Avoid Penalties If They File Delinquent Information Returns Relating to Foreign Accounts, Foreign Entities, and Foreign Gifts.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
Download the file for IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline.
by Michael J. Miller
Published: BNA Tax Management - International Journal, August 13, 2010
Download the file for Tax Court Approves Tax-Free Payment of Outbound Guarantee Fees.
by Michael J. Miller
Published: International Tax Journal, May 2010
Download the file for 2010 FBAR Update.
by Michael J. Miller, Peter H. Blessing
Published: Canadian Tax Foundation - 61st Annual Conference, April 01, 2010
Download the file for Foreign Account Tax Compliance Provisions Have Far-Reaching Effect.
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
Download the file for IRS Issues Relief from FBAR Filing Obligations for Three Groups.
by Michael J. Miller
Published: International Tax Journal, January 01, 2010
Download the file for Reflections on the Application of Income Tax Treaties to Hybrid Entities That Earn Non-FDAP Income.
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
Download the file for IRS Extends Deadline For Voluntary Disclosure Program.
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
Download the file for Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program.
by Ellen Seiler Brody
Published: Journal of Retirement Planning, May 01, 2009
Download the file for Should Retirees Still Consider Expatriating?.
by Mark David Rozen, Ellen Seiler Brody
Published: Rothschild Trust Review, April 01, 2009
Download the file for Proposed Legislation Affecting Assets Held Overseas.
by Ellen Seiler Brody
Published: BNA Tax Planning International Review, December 16, 2008
Download the file for U.S. Adopts Exit Tax Upon Expatriation.
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 17, 2008
Download the file for Forfeiture of Deductions for Failure to File Timely Return: (Swallows Holding, Ltd. v. Commissioner).
by Michael J. Miller
Published: The Canadian Tax Journal, September 01, 2007
Download the file for Proposed Earnings-Stripping Rules May Affect Canadian Investments in the United States.
by Michael J. Miller
Published: International Tax Journal, June 01, 2007
Download the file for Accessing U.S. Income Tax Treaties: Current Trends in the Limitation on Benefits Article.
by Michael J. Miller
Published: Tax Management International Journal, April 13, 2007
Download the file for Notice 2007-13 Announces New and Improved Substantial Assistance Rules.
by Howard J. Levine, Michael J. Miller
Published: International Tax Journal, February 01, 2007
Download the file for Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test.