Jan 19, 2024

The Fog: The Interaction of Treaties & Domestic Tax Law

Michael Karlin presented “The Fog: The Interaction of Treaties & Domestic Tax Law” at the American Bar Association Tax Section Midyear Tax Meeting alongside Ege Berber of PriceWaterHouseCoopers, Qiguang (Hardy) Zhou of Feingold & Alpert, LLP, and Elena Virgadamo, Deputy International Tax Counsel for Treaty Affairs, Department of the Treasury. This comprehensive session covered the relationship of tax treaties and domestic law, as well as Section 960 – Tax Treaties and Indirect Tax Credits, Section 1411 – The Net Investment Income Tax, Section 7701(b) – Tax Treaties and Residence, Section 864(c)(8) – Sale of Partnership Interest by Foreign Person, Section 877A(f) Distributions from Non-Grantor Trusts to Covered Expatriates, and Section 2801 – Taxation of Gifts to and Inheritances Received by U.S. Persons from Covered Expatriates.

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