A profound effect on family controlled businesses may be in store when proposed Treasury Regulations under Section 2704 of the Internal Revenue Code come to pass. Under the new regulations, taxpayers would be precluded from...more
On May 10, 2016, the Treasury Department issued proposed regulations (the Proposed Regulations) which enable the Internal Revenue Service (IRS) to collect certain information about domestic disregarded entities with a single...more
As a jurisdiction, Nevis is highly regarded as setting the standard among offshore trust laws, blazing new trails in this is area since 1994 with other jurisdictions attempting to play catch-up. Over time, other jurisdictions...more
The Internal Revenue Service (IRS) recently announced that starting in 2015, taxpayers who filed their 2014 federal tax return with an address in Florida, Georgia, or Washington, D.C. are eligible to obtain an "identity...more
In Berlinger v. Casselberry, Case No. 2D12-6470, 6 (Fla. 2d DCA Nov. 27, 2013), the Florida Second District Court of Appeal upheld a writ of garnishment issued by a trial court against the trustee of a discretionary trust...more
On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more
On January 17, 2013, the IRS released final regulations for the Foreign Account Tax Compliance Act ("FATCA") to be effective on January 28, 2013. Enacted by Congress in 2010, FATCA targets non-compliant U.S. taxpayers using...more
On January 1, 2013, the Senate passed the American Taxpayer Relief Act, H.R. 8 (the "Bill"), by a vote of 89 to 8. Later that same day, the House of Representatives approved the Bill by a vote of 257 to 167. On January 2,...more
The U.S. Department of Treasury ("Treasury") recently released its second model agreement (the "Model II Agreement") for countries to implement the Foreign Account Tax Compliance Act ("FATCA"). FATCA requires foreign...more
The United States has entered into its second and third bilateral agreements regarding the implementation of FATCA with Denmark and Mexico, respectively. FATCA was enacted in 2010 as part of the Hiring Incentives to Restore...more