Jenny Longman

Jenny Longman

Patterson Belknap Webb & Tyler LLP

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New Rules on Section 83(b) Elections

Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to: - File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more

8/3/2016 - Equity Compensation Filing Requirements IRC Section 83(b) IRS Restricted Stocks Startups Stocks Tax Liability Tax Returns

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

5/19/2016 - Corporate Taxes Domestic Corporations Foreign-Owned Corporations Internal Revenue Code (IRC) IRS Reporting Requirements Tax Treaty

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

7/17/2014 - Credit Suisse DOJ Enforcement Enforcement Actions FBAR IRS Offshore Banks Offshore Funds OVDP Penalties Pre-Clearance Tax Penalties UBS

Who Is a U.S. Person? Disparities Between U.S. Tax and Immigration Law

The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more

3/15/2014 - Citizenship Disparate Treatment Estate Tax Exit Tax FATCA FBAR Income Taxes IRS Lawful Permanent Residents U.S. Person

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

1/11/2013 - Alternative Minimum Tax American Taxpayer Relief Act Capital Gains Dividends FATCA Fiscal Cliff Foreign Earned Income Foreign Nationals Foreign Tax Income Taxes Itemized Deductions Payroll Taxes Personal Exemptions Tax Exemptions Tax Rates

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