Category: International Taxation

The US tax reform (or “Tax Cuts and Jobs Act”) was enacted on 22 December 2017 with most of the international provisions in force since the beginning of 2018.  The US tax reform includes both tax-reducing and tax-increasing measures, which generate new planning opportunities.

This brief will describe the obligations for … Read More..

On July 13, 2017, the U.S. Tax Court released Grecian Magnesite Mining, Industrial & Shipping Co., S.A. v. Commissioner, 149 T.C. No. 3 (July 13, 2017) (available here), in which it declined to follow the IRS’s position in Revenue Ruling 91-32, 1991-1 C.B. 107 (the “Ruling”).  In the Ruling, the … Read More..

Several international tax treaties of which Israel is a member incorporate the term “permanent establishment”. The term bears practical significance in matters concerning immigrant and returning resident tax. What is a “permanent establishment”? By which criteria will an establishment be defined as such? What should immigrants be aware of? What … Read More..

Over the years, one of the most important questions entrepreneurs and innovators occupied themselves with was “how to raise money to fund my project\company?”. Before 2013 the answer to this question was quite limited and consisted of two main options:

Finding private investors who would agree to put their money … Read More..

Two years ago, in June 30th 2014, Israeli and American governments signed an agreement to implement FATCA regulations in Israel. The agreement necessitates the local banks and other financial institutions to transfer information regarding bank accounts, financial assets and income of US citizens with Israeli accounts and Israeli citizens with … Read More..