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U.S. Pre-Immigration Tax Planning (UPDATED)

There are no adverse consequences, other than transaction costs, to engaging in tax planning before immigrating to the United States. However, there may be significant adverse tax consequences if you fail to engage in any tax...more

Loan Restructuring and Forbearance Agreements in the Face of COVID-19 – The Lender’s Perspective

The last few weeks have been very rough on borrowers, particularly in the hospitality and retail industries. Although there are a lot of unknowns surrounding COVID-19 and its impact on our health and economy, we do know that...more

Partnerships Must Respond to New Audit Rules

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

New FIRPTA Exceptions Provide Opportunities for Foreign Pensions and Investment Funds

The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) authorized the United States to tax foreign persons on the gain from the disposition of U.S. real property or U.S. real property interests (USRPIs). Recently,...more

IRS Targets Captive Insurance Companies Owned by Closely-Held and Middle Market Companies

In February 2015, the IRS added certain small or “micro” captive insurance companies to its “Dirty Dozen” list of abusive tax scams for the 2015 filing season. In response to what it sees as an abuse involving a...more

Expansion of Fiduciary Duties Will Impact Florida LLCs – Is it Time to Update Your Operating Agreement?

Amendments to the Florida Revised Limited Liability Company Act go into effect on July 1, 2015. It governs all limited liability companies in the state of Florida. Effective July 1, 2015, the Act was amended, in part, to...more

Q&A With Carlton Fields Jorden Burt's David Burke

David P. Burke is a shareholder in the Tampa office of Carlton Fields Jorden Burt PA and chairman of the firm’s tax practice. Burke’s practice focuses on federal, state and international taxation planning and business...more

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