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U.S. Estate and Gift Tax Exposure

07.21.20
When non-U.S. citizens live, work or own property in the U.S., the tax implications are not always cut and dry. Whether in the United States indefinitely or for a long-term assignment, non-U.S. citizens are considered domiciled if they do not have th...
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COVID-19’s Effect on Transfer Pricing 

05.11.20
Transfer pricing documentation requirements have globally become increasingly universal, and certain transfer pricing positions are also widespread. As the economy continues to suffer from the COVID-19 pandemic, it begs the question as to why some tr...
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Final Regulations Address Foreign Tax Credit

01.30.20
The Internal Revenue Service (IRS) has issued highly anticipated final regulations on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The final regulations retain the basic approach and...
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