Proposed and Temporary Regulations for Foreign Tax Limitation Purposes

Summary The Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “Service”) have issued Proposed and Temporary Regulations under Internal Revenue Code (“IRC”) Section 901(m). The Proposed and Temporary Regulations contain rules that limit the ability to claim foreign tax credits that arise from certain types of transactions. Background On August 10, 2010, Section 212 of the Education […]

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Year End Tax Planning Client Letter

Dear Client: As the end of the year approaches, it is a good time to think of planning moves that will help lower your tax bill for this year and possibly the next. Factors that compound the planning challenge this year include turbulence in the stock market, overall economic uncertainty, and Congress’s all too familiar failure to act on a […]

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Five Last Minute Moves to Lower Your 2015 Tax Bill

Tax Day is right around the corner. Have you filed your federal tax return yet? The filing deadline to submit 2015 individual federal income tax returns is Monday, April 18, 2016, rather than the traditional April 15 date. Washington, D.C., will celebrate Emancipation Day on Friday, April 15, which pushes the deadline to the following Monday for most of the […]

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