Author Page: Neha Rastogi — Ruchelman P.L.L.C.

Author Page: Neha Rastogi — Ruchelman P.L.L.C.

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Webinar | G.I.L.T.I. Tax: Inclusion, Reporting, Exceptions

Inside the Global Tax Practice: A Seminar on U.S. International Tax Planning

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When Baskets Go Beyond Weaving – Understanding Foreign Tax Credit Baskets Under the Look-Through Rules

French Life Insurance “101” – For U.S. Persons, Run Away

Unravelling of the Matryoshka Doll – Impact of the C.T.A. on entities having nexus to the U.S.

Did You Just Manifest the Opposite of What You Wanted - (IN)Ability to Use G.I.L.T.I. Losses to Offset Gain

Too Bad To Be True – Code §§267A and 894(c) Signal the End for Cross Border Hybrids

Late Filed Form 3520 – What Penalties to Expect and How to Respond

The More You Know, The More You Don't Know – U.S. Tax Issues on a Disposition of a Foreign Business

Rescission – Undoing a Transaction That Seemed Like a Good Idea at the Time

Taxation in India and the U.S.: Stages in the Life of a U.S. Owned Indian Company

The 15 Most Important Questions That Should Be Asked When Estate Planning for a Foreign Parent with U.S. Children

With Great Power (Control) Comes Great Responsibility – Form 5471 Category 4 Filer

Final G.I.L.T.I. High-Tax Regulations and the Tested Unit: Would a Rose by Any Other Name Smell as Sweet?

Heads I Win, Tails You (I.R.S.) Lose – Not Any More: Hybrid Dividends And Code §245A(e)

Variety Is the Spice of Life: Alternate Tax Structures for a U.S. Individual Disposing of Foreign Real Property

Same Same, But Different: Taxing a Sale of Indian Stock by a U.S. Person

Domestic Partnerships Treated as Entities and Aggregates: New Approach for G.I.L.T.I. and Subpart F

Preferred Yet Neglected — A Plea for Guidance on Redemptions of C.F.C. Preferred Stock in the Wake of U.S. Tax Reform

Is the 100% Dividend Received Deduction Under Code §245A About as Useful as a Chocolate Teapot?

Peeling the Onion to Allocate Subpart F Income – This Will Make You Cry!

It’s Time for Cayman Shell Entities to Come Out of Their Shells and Show Economic Substance

More Permanent Establishments: The Dwindling Preparatory and Auxiliary Activities Exception

Insights Vol. 6 No. 2: Updates & Other Tidbits

Mirror, Mirror, On the Wall, Which Is My Tax Home of Them All? – Foreign Students Face Dilemma in the U.S.

Qualified Business Income – Are You Eligible for a 20% Deduction? Part II: Additional Guidance

Insights Vol. 5 No. 8: Updates & Other Tidbits

Insights Vol. 5 No. 6: Updates & Other Tidbits

The F-1 Visa – Privileged U.S. Tax Status and How to Keep It

Investing in U.S. Real Estate on a (Possibly) Tax-Free Basis

Changes to C.F.C. Rules – More C.F.C.’s, More U.S. Shareholders, More Attribution, More Compliance

Insights Vol. 5 No. 1: Updates & Tidbits