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Publications by Kenneth Lobo

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articles from insights
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I.R.S. Pushes to Ease Implementation of Country-by-Country Reporting for U.S. M.N.E.’s
Foreign Tax Credit May Not Be Available for Gains Derived Outside the U.S.
Code §163(J) – Ignoring U.S. Thin Capitalization Rules May Leave Tax Advisors Thinly Prepared for Audits
Valuation – More Art than Science
Cross-Border Complexities: What You Need to Know Before Your Non-U.S. Client Invests in the U.S.
Implementing the Border Adjustment Tax: Winners & Losers
Debt v. Equity: Judicial Factors Still Applicable Post-§385 Regulations
Transfer Pricing Adjustment Does Not Reduce Dividend Received Deduction from C.F.C.
European State Aid: The Makings of A Global Trade War
The 2016 U.S. Model Income Tax Treaty
I.R.S. Adds New Theory Why Merger Termination Fees are Capital Rather than Deductible Costs
Insights Vol. 3 No. 9: Updates & Other Tidbits
Projected Tax Expense – Can It Be Computed on the Back of Envelope?
Treasury Attacks European Commission on State Aid – What Next?
O.E.C.D Targets Hybrid Mismatch Arrangements Using Branch Structures
Insights Vol. 3 No. 7: Updates & Other Tidbits
Tax 101: Foreign Settlors, U.S. Domestic Trusts, and U.S. Taxation
I.R.S. Issues Proposed Regulations Affecting Valuation Discounts for Gift and Estate Tax Purposes
Insights Vol. 3 No. 6: B.E.P.S. Around the World
Draft Valuation Rules for Indirect Transfers in India
Insights Vol. 3. No. 5: B.E.P.S. Around The World
Insights Vol. 3 No. 4: B.E.P.S. Around The World
Transfer Pricing Positions of Consolidated Groups: After Guidant
Country-by-Country Reporting – Where Are We Going?
Insights Vol. 3 No. 3: Updates & Other Tidbits
2016 Model Treaty – Mandatory Arbitration
International Practice Unit: I.R.S. Releases Subpart F Sales and Manufacturing Rules
Insights Vol. 3 No. 1: Updates & Other Tidbits
Anti-Inversion Rules Expanded
Russian Recovery Fund v. U.S.

other publications
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Featured
Contract Manufacturing in a US-Controlled Group

First published by the Canadian Tax Foundation in (2016) 24:7 Canadian Tax Highlights.

U.S. Immigration Tax Planning – Covered Expatriates

Published in Taxes & Wealth Management by Thomson Reuters, Issue 9-1: February 2016. (p.14)

IRS Faces House Concerns About BEPS Initiative’s Impact on U.S. Companies

Published in GGi FYI International News No. 4, Spring 2016 (p.12).

Planning for Canadian Parents with U.S. Children

Published in Taxes & Wealth Management by Thomson Reuters, Issue 8-4: November 2015.

Indian Investors Purchasing U.S. Real Estate – From a U.S. Point of View

Published in International Taxation, Volume 13, Issue 3: September 2015.

Tax Planning for Indian Businesses Investing in the US – Part II

Published in Taxsutra: September 2015.

Indian Businesses Investing in the US – Tax Challenges – Part I

Published in Taxsustra: September 2015.

The US Net Investment Income Tax

First published by the Canadian Tax Foundation in (2015) 23:6 Canadian Tax Highlights.

U.S. Holiday Homes - Top 10 Tax Issues to Remember

Published by GGi in International Taxation News, No. 3: Spring 2015.

Guidance for Canadian Snowbirds

Published in The Bottom Line, December 2014.

US-Based Pushback on BEPS

Published in Intertax, Volume 43, Issue I: 2015.

The U.S. View on B.E.P.S.

AOTCA 2014 Conference, October 2014.

presentations
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Featured
U.S. Citizens as Shareholders of Canadian Companies – Impact on Reorganizations and Other Canadian Tax Consequences

First presented at the Canadian Tax Foundation’s 68th Annual Tax Conference (2016) in Calgary, AB.

T & E Planning Tidbits from Canada and France
The Life of an Outbound Investment from the U.S. into Canada