On September 27, Republican leadership from the House, Senate, and the Trump administration released the “Unified Framework for Fixing Our Broken Tax Code” (the “Framework”). The Framework outlines, in largely broad, general terms, the Republican goals and vision for comprehensive tax reform. The reform’s stated goals include increasing simplicity, providing tax relief for businesses and middle-class families, and ending incentives to ship jobs, capital, and tax revenue ... Keep Reading »
Statute of Limitations and International Reporting Obligations – Be Sure to Close the Door!
When it comes to federal tax matters, an important aspect of risk management includes making sure that the statute of limitations on tax assessments will expire. This is particularly important for tax years where there is a potentially contentious issue or debatable reporting position taken on the treatment of a material item. However, increasing reporting burdens imposed on international activities coupled with exceptions to the statute of limitations heighten the ... Keep Reading »
Foreign Partner’s Gain on Disposition of U.S. Partnership Interest Is Not Taxable
After great anticipation, the Tax Court has held that gain realized by a foreign corporation upon the redemption of its interest held in a U.S. partnership is non-U.S. source capital gain that was not effectively connected with a U.S. trade or business. As such, U.S. income tax could not be imposed on the gain. Although the wheels of justice often turn slowly, the Tax Court ultimately got taxpayers to the right answer in Grecian Magnesite Mining, Industrial & ... Keep Reading »