The complexities of US taxation, particularly Unrelated Business Taxable Income (UBTI), can deter European private equity firms looking to unlock the lucrative US pension funds market, but learning how to navigate them really is worth the effort. European PE is driven by a fiercely competitive marketplace and the US, home to about half of the […]

Even as venture capital markets expand around the world and forge new hubs for business, the unique allure of the US remains constant. The US boasts a vast and affluent base of consumers, robust supply chains and infrastructure, as well as a wide diversity of markets. At some point most businesses will think about US […]

American citizens and resident aliens are all too familiar with the IRS practice of worldwide taxation. For most expats, this simply means having to file an additional tax return each year. But where the rules can get complex and, in many cases counter-intuitive, is where these rules extend their reach into overseas assets owned by […]

When President Joe Biden entered office at the beginning of this year, he did so with ambitious plans to reshape the US tax landscape in a more progressive fashion. As the White House continues to grapple on a broader legislative package with its razor-thin majority in Congress, we caught our first glimpse of the new […]

It seems nearly impossible today to have a conversation about technology or finance without ultimately turning towards the subject of cryptocurrency. It’s a topic that equally dominates the discussion at Web Summit and the Wall Street Journal alike, is discussed on mainstream news around the world, and whether or not you have mastered all the […]

Update: Since this blog was posted, the IRS issued proposed regulations, on March 3, 2019, that clarifies that the 50 percent deduction discussed in item 5 will be available to individual shareholders who elect to be taxed as a corporation.   Last year we provided an early update that all US shareholders of Controlled Foreign Corporations (CFC) […]

The US Supreme Court has delivered its verdict in the case of South Dakota v. Wayfair Inc et al this week, in a move which could drastically change the nature of online retail in the United States. The ruling, which overturned the 1992 decision of Quill Corp v. North Dakota, has substantially freed state and […]