International Taxation

Transfer Pricing and Transfer of Property Outside the US

Transfer Pricing and Transfer of Property Outside the US [...]

Transfer Pricing and Transfer of Property Outside the USSteve Yahnian2020-03-16T18:03:01-07:00

Subpart F Income When a US person owns shares [...]

Subpart F IncomeSteve Yahnian2020-03-16T17:58:19-07:00

Controlled Foreign Corporations Now we are going to switch [...]

Controlled Foreign Corporations (CFCs)Steve Yahnian2020-02-17T18:11:03-07:00

Branch Profits Tax and FIRPTA Where we are to date: [...]

Branch Profits and FIRPTASteve Yahnian2020-02-06T15:50:18-07:00

Decision Tree 1: Inbound Transactions Analysis for Foreign Persons or [...]

Decision TreeSteve Yahnian2020-02-06T15:49:02-07:00

I will elaborate on the following four areas: Capital Gains [...]

Other In Bound RulesSteve Yahnian2020-02-06T15:47:59-07:00

Inbound Transactions - Business Income "Business Income" is income that [...]

In Bound Transactions-Business IncomeSteve Yahnian2020-02-06T15:45:34-07:00

Inbound Transactions - Non-Business Income Now that we’ve distinguished between [...]

Inbound Transactions – Non-Business IncomeSteve Yahnian2020-02-06T15:43:38-07:00

Source Rules for Income I/ Interest: Rule: Residence of Payor [...]

Sourcing Rules ExamplesSteve Yahnian2020-02-06T15:41:40-07:00

I will elaborate on the following areas: Difference between a [...]

Corporations and BranchesSteve Yahnian2020-02-06T15:38:59-07:00