2025 Australian Federal Budget Summary On Tuesday, March...
In our 13th installment of the Family Office...
2024 Australian Federal Budget Summary On Tuesday 14th...
“Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”
The Code employs various definitions of what constitutes “ownership” in various circumstances, and with regards to the classification of foreign companies as CFCs,... Read more
The “Controlled Foreign Corporation” Regime: What is a CFC Anyway?
While the U.S. tax system appears to be federal in nature, the U.S. uses the Internal Revenue Code to cast a wide web... Read more
Is a Nonresident Alien’s Sale of a Partnership Interest a U.S. Trade or Business?
Our previous post, The Code Fails to Define a “U.S. Trade or Business,” even though You’re Still on the Hook for Paying Taxes... Read more
The Code Fails To Define A “U.S. Trade Or Business,” Even Though You’re On The Hook For Paying Taxes On It
As mentioned in our prior post, Even Nonresident Aliens may be Taxable in their U.S.-Sourced Income, a nonresident alien will be liable for... Read more
Even Nonresident Aliens may be Taxable on their U.S.-Sourced Income
A nonresident alien of the United States will be subject to U.S. taxation if they have income that is “effectively connected” with a... Read more
U.S. Residents are taxable, U.S. Persons: So, What is a “U.S. Resident”?
Under the Internal Revenue Code a Person is liable for fulfilling their U.S. tax obligations if they are a “resident” of the United... Read more