This course will examine complex tax clauses in operating agreements to assist tax practitioners in identifying and implementing these key provisions in accordance with partners' expectations and existing regulations. Read More Partnership Debt: Allocating Liabilities and Associated Deductions Recourse vs...
By integrating provisions such as a “floating spouse” clause and adhering to the Health, Education, Maintenance, and Support (HEMS) standard, practitioners can mitigate these risks and enhance the trust’s effectiveness. Ultimately, as the landscape of estate planning continues to shift, the ...
The law “On Taxes and Fees”, Article 18, the first part of Clause 2. The law “On the State Revenue Service”, Article 2, Clause 1. The law “On the State Revenue Service”, Article 8, Clause 8. References Abdukadirov, S. (Ed.). (2016). Nudge theory in action: Behavioral des...
(a) If SpinCo notifies Parent that it desires to take one of the actions described in clauses (i) through (vi) of Section 8.02(c) (a “Notified Action”), Parent and SpinCo shall reasonably cooperate to attempt to obtain the Unqualified Tax Opinion or supplemental ruling from the IRS ref...
Dividends Tax and Double Taxation Agreements: ‘Dutch Most Favoured Nation’ Clause November 05, 2018 Download PDF - 165 KB Tax amnesty in Italy: New measure allows taxpayers to 'find peace' with the Revenue Agency April 04, 2018 Download PDF - 128 KB US 2017 APA report reflects ...
In the investment regime, treaty shopping has been addressed through anti-abuse doctrines, through definitions of the concept of “investor” or of the concept of the “home state” of the investor, or through specific denial of benefit clauses. The Model bilateral investment agreement developed ...
Therefore, the saving clause overrides Article 17(2) and allows the United States to tax a lump-sum payment received by a U.S. resident from a U.K. pension plan. Is it better to take a lump-sum or monthly payments? In most cases, the lump-sum option is clearly the way to go....
Expense side TDS compliance for clause 34 Tax Technology - Practice Overview Form 26AS Reconciliation - Product Overview Insolvency and Bankruptcy Code While the Goods and Service Tax (GST) has been widely described as independent India’s biggest tax reform after the economic liberalisation of 1991...
A second challenge asserts that the tax violates the equal protection clauses of the California and US Constitutions. While the various challenges were filed prior to the tax’s effective date, no court has issued an injunction prohibiting LA County from collecting the tax. However, if the tax...
On December 5, 2023, the U.S. Supreme Court heard oral arguments in the tax caseMoore v. United States, Docket No. 22-800.[ix]The taxpayer argued that the transition tax under Code Section 965 is unconstitutional, claiming it violates the Apportionment Clause and the Due Process Clause of...