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Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids - Withholding Tax - Vimarsana News

Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids - Withholding Tax

If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.

Source: mondaq.com
Attentione! International Employment – US Employees In Italy - Employee Benefits & Compensation - Vimarsana News

Attentione! International Employment – US Employees In Italy - Employee Benefits & Compensation

The U.S. employer should first evaluate and consider engaging an employer of record who is active in such services in the country where the U.S. citizen will perform the work.

Source: mondaq.com
U.S. Tax Review: APA Update; Perrigo; Rawat, Kyocera, Mann; Cryptocurrency; Net Investment Income Tax - Transfer Pricing - Vimarsana News

U.S. Tax Review: APA Update; Perrigo; Rawat, Kyocera, Mann; Cryptocurrency; Net Investment Income Tax - Transfer Pricing

The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation...

Source: mondaq.com
Is The N.I.I.T. An Income Tax, A Social Security Tax, Or Neither? Double Taxation Of Income Hangs In The Balance - Tax Authorities - Vimarsana News

Is The N.I.I.T. An Income Tax, A Social Security Tax, Or Neither? Double Taxation Of Income Hangs In The Balance - Tax Authorities

Congress enacted the N.I.I.T. in 2012 as part of a 2010 law amending the Affordable Care Act ("A.C.A."), more popularly known as "Obamacare." Its creation corresponded to a 0.9% increase...

Source: mondaq.com
A guide to filing US taxes for expats living in the Netherlands in 2022 - Vimarsana News

A guide to filing US taxes for expats living in the Netherlands in 2022

For American expats living in the Netherlands in 2022, filing both Dutch and US taxes might seem like a long process. Luckily, Bright!Tax has put together a...