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On October 23, 2014, the Internal Revenue Service (IRS) announced the tax-year 2015 cost of living adjustments (COLAs) affecting the dollar limitations for pension plan contributions and plan contributions for other retirement-related plans. While many pension plan limitations will change for 2015 because the COLAs met the statutory thresholds triggering their adjustment, not all limitations […]
On September 22, 2014, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued Notice 2014-52, “Rules Regarding Inversions and Related Transactions” (“Notice”) in the wake of recent inversions conducted by many US companies such as by Medtronic, Chiquita Brands, Pfizer and others. Treasury and the IRS highlighted in the Notice that […]
On September 3, 2014, the IRS announced that the underpayment and overpayment interest rates for the fourth quarter of 2014 will remain the same The rates will be: three (3) percent for overpayments (two (2) percent in the case of a corporation); three (3) percent for underpayments; five (5) percent for large corporate underpayments; and […]
In this article we will briefly examine the treatment of the business profits of a resident of a contracting State under the Canada-US Income Tax Convention, and the important definition of a “permanent establishment” for purposes of determining the potential taxability of income of such profits. This article is intended to provide informative material for […]
There is a great deal of confusion about the reporting of foreign gold and silver storage accounts on the Report of Foreign Bank and Financial Accounts (FBAR). In this article, I would like to set forth the general legal framework for the analysis of the reporting requirements for the foreign gold and silver storage accounts. […]