In a decision
released July 13, the U.S. Tax Court held that gain realized by a non-U.S. investor on the disposition of an interest in a partnership that operated a U.S. business was gen...
On November 2, 2011, Treasury released proposed revisions to the regulations under Section 892 of the Internal Revenue Code of 1986 (the “Code”). Section 892 provides an exemption fro...
Today, the IRS released guidance that provides significant relief to persons considering the extent to which they need to submit a Report of Foreign Bank and Financial Accounts (an “FBA...
The Treasury Department has released proposed regulations that would provide some relief to filers attempting to determine their obligations under the rules regarding the Report of Foreig...