This is because, for US tax purposes, gain on the sale of property is generally treated as tax-free foreign source gain in the hands of a foreign seller.
In particular, the Final Regulations adopt a new “attribution requirement” (Attribution Requirement) that restricts the availability of FTCs to foreign taxes that the Treasury and the IRS consider to be similar to US taxes.
North America recorded 15% revenue growth, with consulting services growing by a blistering 50% in 2021. RSM’s Europe and Africa regions also had 15% revenue increases, while the Middle East grew 23%, Asia grew 20%, and Latin America grew 11%.
Though many of Democrats’ more radical tax proposals were scaled back or dropped in negotiations, the bill would be “a meaningful step for reducing inequality,” said Carl Davis
An oligarch, a dictator’s aide and a beverage tycoon turned to America’s least populated state to shelter assets, the Pandora Papers show.
Following is a brief summary of certain BBBA concepts which, if enacted in its current form, would potentially increase the overall tax burden on certain parties involved in private equity mergers and acquisitions (M&A) transactions and may have year-