-
What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. V. Israel Tax Authority, Means for U.S. Multinationals
The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes. The ruling clarifies how contingent…
-
How Limited Partnerships Are Taxed in the U.S.: Insights, Advantages, and Drawbacks from a U.S. Tax Lawyer
An Overview of U.S. Limited Partnerships A Limited Partnership (LP) is a pass-through entity formed under state law that includes at least one general partner (GP) and one or more…
-
IRS Reverses Course on DeFi Broker Rule: Impact on U.S. Crypto Investors and DeFi Platforms
Overview The U.S. cryptocurrency sector continues to evolve as regulators clarify crypto tax obligations. In April 2025, Congress overturned the IRS’s proposed expansion of the “broker” definition under the Infrastructure…
-
![Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law](https://taxlawyer.com/wp-content/uploads/2025/10/Handcuffs-on-top-of-a-stack-of-American-currency-with-tax-forms-beneath-it-on-a-desk-768x512.jpeg.webp)
Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law
The Economic Substance Doctrine, codified under IRC §7701(o), is a critical anti-abuse rule in U.S. tax law. It ensures transactions have both a meaningful economic effect and a legitimate non-tax…
-
U.S. Life Insurance Withdrawals: Tax Implications and Strategies
Permanent life insurance policies—such as whole life, universal life, and variable life—are valuable financial tools that provide both protection and cash value accumulation. Understanding how withdrawals are taxed helps policyholders…
-
Israel’s 2025 Voluntary Disclosure Procedure: Updates and Clarifications for U.S. Taxpayers with Israeli Ties
August 2025 Changes: Launch of the New Israeli Voluntary Disclosure Procedure (VDP) In August 2025, the Israeli Tax Authority (ITA) introduced a new Voluntary Disclosure Procedure (VDP), designed to allow…
-
How Americans Must Report ‘Spin-Off’ Shares under Section 355 of the Internal Revenue Code (IRC) in the U.S.
U.S. corporations occasionally restructure by separating one part of their business into a new corporation and distributing shares of the new company to existing shareholders. For U.S. residents, these shares…
-
U.S. Reporting Requirements for Cross-Border, Related-Party Transactions: What U.S. Taxpayers Must Know Now for Compliance
Understanding the U.S. Equivalent to Canada’s T106 In Canada, taxpayers must file CRA Form T106 to disclose certain non-arm’s length transactions with non-residents. The United States does not have a…
-
Why Passive Foreign Investment Companies (PFICs) Can Have Severe Tax Consequences: A Guide for U.S. Taxpayers
Overview: Why PFIC Rules Matter Many U.S. taxpayers with global investments are unaware of the harsh U.S. tax rules that apply to Passive Foreign Investment Companies, commonly known as PFICs.…
-
Case Comment: CFM Insurance, Inc. v. Commissioner – What American Taxpayers Should Know About How the IRS Views Microcaptive Arrangements v Tax Avoidance Schemes
Court: U.S. Tax CourtDate: August 4, 2025Citation: T.C. Memo. 2025-83 Facts CFM Insurance, Inc., a microcaptive insurance company, was established to provide insurance coverage to its parent company, Caputo’s New…
