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Author Archives: James Debate

About James Debate

James Debate is a Corporate Senior Tax Associate with US Tax & Financial Services.

The New Cryptocurrency Tax Bill: If it ain’t broker, don’t fix it!

When President Joe Biden entered office at the beginning of this year, he did so with ambitious plans to reshape the US tax landscape in a more progressive fashion. As the White House continues to grapple on a broader legislative package with its razor-thin majority in Congress, we caught our first glimpse of the new […]

A guide to the US Taxation of Cryptocurrency

It seems nearly impossible today to have a conversation about technology or finance without ultimately turning towards the subject of cryptocurrency. It’s a topic that equally dominates the discussion at Web Summit and the Wall Street Journal alike, is discussed on mainstream news around the world, and whether or not you have mastered all the […]

Update: GILTI tax

Update: Since this blog was posted, the IRS issued proposed regulations, on March 3, 2019, that clarifies that the 50 percent deduction discussed in item 5 will be available to individual shareholders who elect to be taxed as a corporation.   Last year we provided an early update that all US shareholders of Controlled Foreign Corporations (CFC) […]

Dot-com Rubble: Supreme Court Affirms Online Sales Tax Expansion in Landmark Case

The US Supreme Court has delivered its verdict in the case of South Dakota v. Wayfair Inc et al this week, in a move which could drastically change the nature of online retail in the United States. The ruling, which overturned the 1992 decision of Quill Corp v. North Dakota, has substantially freed state and […]

US Tax Reform: Is Your Business Affected by TCJA?

How will the new law affect your business? The Tax Cuts and Jobs Act of 2017 (TCJA) has recently been signed into law and will enact significant changes to the US tax code. For businesses looking to expand into the United States, the prospect of navigating a new regulatory landscape can present a daunting challenge. […]

Hands-off Management: Foreign investors score victory in US Tax Court ruling

On 13 July, the US Tax Court dealt a blow to the Internal Revenue Service (IRS), and relief to foreign investors, with its ruling in Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue. When Grecian Magnesite Mining (GMM), a foreign corporation, sold its interest in Premier Chemicals, a US LLC, […]

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