Jeffrey L. Rubinger is a partner in Bilzin Sumberg Baena Price & Axelrod's Miami office. He practices in the area of domestic and international taxation.
Originally Published on Law360 - January 31, 2014. ...more
Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more
Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries.
Originally Published in Law360 - October 29,...more
Pass-through structures -
Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more
Proposed Regulations (REG-161948-05, 9/6/13) dealing with the importation of built-in loss properties under Sections 334(b)(1)(B) and Section 362(e)(1) are designed "to prevent erosion of the corporate tax base through the...more
Non-U.S. taxpayers are generally exempt from U.S. federal income tax on gain from the sale of U.S.-situs capital assets. The one major exception is U.S. real estate. Under the Foreign Investment in U.S. Real Property Tax...more
The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more
As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more
Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more
The combination of a weak U.S. dollar and low interest rates has resulted in more foreign investment in U.S., and South Florida, commercial real estate. But one of the primary obstacles facing foreign persons who invest in...more