Does your business need a private letter ruling from the IRS?

Tax planning is crucial for the growth of any business. Unfortunately, there are situations where a business would like to engage in a transaction and the IRS has issued no guidance as to how that transaction should be treated for tax purposes.
Foreign Investment in Real Property Tax Act (FIRPTA) Withholding

The Foreign Investment in Real Property Tax Act (FIRPTA) is a federal law that requires foreign persons to pay taxes on their gains and income from U.S. real estate investments.
Double Tax Avoidance Agreements Between USA and Other Countries

As governments around the world struggle to balance their national budgets, many countries are turning to Double Tax Avoidance Agreements (DTAAs) in order to minimize taxes and ensure equitable collection of revenue between two different nations.