Recent Posts in the International Tax Category

• The UK LTA Charge Can Be Claimed as a Foreign Tax Credit
  Feb 21, 2019
  by John Anthony Castro, J.D., LL.M. Introduction Although this article concludes that the Lifetime Allowance Charge, also known as the LTA Charge, is ...
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• Roth Accounts are Exempt from U.K. Tax
  Feb 18, 2019
  by John Anthony Castro, J.D., LL.M. Introduction In summary, by operation of the U.S.-U.K. Income Tax Treaty, any pension exemption in one country is ...
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• The 2019 Offshore Voluntary Disclosure Program
  Feb 8, 2019
  by John Anthony Castro, J.D., LL.M. Introduction On November 20, 2018, the Deputy Commissioner for Services and Enforcement, Kirsten B. Wielobob, ...
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• The Treaty Definition of a Permanent Establishment
  Feb 7, 2019
  Introduction Although this article focuses on the United States, we advise clients worldwide on structuring operations to avoid the finding of a ...
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• The Net Investment Income Tax is Eliminated by Totalization Agreements
  Feb 5, 2019
  by John Anthony Castro, J.D., LL.M. Introduction One of the most common and frequent questions we get from clients outside of the U.S. is “why do I ...
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• The New Section 163(j) Interest Limits and the Portfolio Interest Exemption
  Feb 4, 2019
  by John Anthony Castro, J.D., LL.M. Introduction On December 22, 2017, the President signed into law the Budget Fiscal Year 2018, which made drastic ...
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• NQDC Plans Are Eligible for Treaty Pension Benefits
  Feb 3, 2019
  Introduction Income tax treaties simplify and resolve a lot of cross-border tax matters. Unfortunately, most firms don’t generate revenue when matters ...
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• Reasonable Cause to Avoid Tax Penalties
  Jan 31, 2019
  Introduction What constitutes “reasonable cause” under Code section 6651 for purposes of avoiding penalties for failure to file a tax return or pay ...
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