The International Tax Journal

The International Tax Journal articles

392 total articles

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Recently added articles from The International Tax Journal:

International Tax Reform: Planning Signposts for U.S. Multinationals
January 1, 2018 ... The recent Tax Act made a number of significant changes to the rules that apply to the foreign operations of U.S. multinational corporations. The new rules require a review of a company's existing global structure which may indicate that changes...

Seeking Closure on Tax Positions: A Look at Tax Statutes of Limitation
January 1, 2018 ... Statutes of limitation... are by definition arbitrary, and their operation does not discriminate between the just and the unjust claim, or the voidable and unavoidable delay." (1) As "applied in the field of taxation, the taxpayer sometimes get...

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders
January 1, 2018 ... In Depth Effective for the first tax year of a controlled foreign corporation (CFC) beginning after December 31, 2017, any U.S. person who is a U.S. shareholder of a CFC and directly or indirectly owns stock in the CFC on the last day of the...

Willful FBAR Penalty Case Shows Importance of Privileged Communications: What Kelley-Hunter Adds to the Foreign Account Defense Discussion
January 1, 2018 ... Introduction There is an old saying that the fish dies by his mouth, which generally refers to the fact that people get into trouble because of what they say, just like the fish meets its doom by swallowing the hook. This saying applies in...

The Level of Tax Complexity: A Comparative Analysis between the U.K. and Turkey Based on the OTS Index
January 1, 2018 ... The hardest thing in the world to understand is income tax. Albert Einstein, Attributed 1. Introduction It is over a decade since Picciotto (1) considered some of the proposals for "improving tax...